ICF International
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Rulemaking Support

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Rulemaking Support

ICF International offers a full range of services to assist clients who develop and promulgate regulations. We provide technical analysis and research, policy analysis, drafting support, comment summarization, and economic analysis.

Our multidisciplinary staff includes economists, attorneys, policy analysts, and other specialists. The firm has experts who specialize in particular types of regulatory analyses, including information collection requests (ICRs), regulatory flexibility analyses, environmental impact analyses under the National Environmental Policy Act (NEPA), and environmental justice analyses.

Recognizing our expertise in the regulatory process, our clients have hired us to draft manuals on their regulatory processes and appropriate methods for developing specific document and analyses, such as ICRs, regulatory impact analyses, and Small Business Regulatory Enforcement Fairness Act (SBREFA) analyses.

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SELECTED PROJECTS
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SELECTED CLIENTS
  • U.S. Department of Commerce, National Oceanic and Atmospheric Administration
  • U.S. Department of Housing and Urban Development
  • U.S. Department of Justice, Drug Enforcement Administration
  • U.S. Department of Transportation, Federal Aviation Administration
  • U.S. Department of Transportation, Federal Highway Administration
  • U.S. Environmental Protection Agency
  • U.S. Nuclear Regulatory Commission
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DETAILS OF SELECTED PROJECTS

Regulation Development Handbooks for the U.S. EPA

For EPA's Office of Solid Waste and Emergency Response, ICF International developed a detailed handbook on the regulatory development process. The handbook addresses each of 30 key steps in the process and contains EPA internal guidelines and procedures on each of the key steps. It also includes examples of completed forms, guidelines prepared by OMB and the Office of the Federal Register, and other necessary supporting documents. ICF International also developed similar handbooks for other clients.

Diversion Control Rules, for the DEA

ICF International is supporting DEA in a comprehensive regulatory reinvention program that includes helping with policy notices, draft preambles, and rule language. For example, we have drafted notices on the Internet sales of controlled substances, the use of the Internet for selling over-the-counter drugs containing listed chemicals, and the use of the Internet for arranging international sales of chemicals. We also have helped draft proposed rules on the importation of controlled substances for personal use and the registration of practitioners working in different states.

Commercial Space Transportation Rules for the U.S. DOT

ICF International provided extensive rulemaking support to DOT on the licensing of commercial space launch facilities and operators. Because commercial space launch facilities are just beginning to come on line, our support included researching novel legal, regulatory, and technical issues. We also participated in the work group that is developing the regulations and helped draft regulatory and preamble text.

Economic Analysis Guidelines for the U.S. EPA

ICF International managed a major revision of EPA's Office of Policy's Economic Analysis Guidelines. We restructured and updated the Guidelines to incorporate recent advances in applied environmental economics and the results of the Economic Consistency Project on social discounting, baseline specification, and other topics. As part of this support, we developed a series of case studies to demonstrate in practical terms various methodological and other issues central to conducting regulatory impact analyses, including social discounting, equity, baseline specification, non-monetized costs and benefits, fatal risk valuation, and uncertainty.

Underground Storage Tank Rules for the U.S. EPA

ICF International has provided comprehensive rulemaking support to EPA's Office of Underground Storage Tanks (USTs) since the inception of that office in the mid 1980s. We performed the original market studies and regulatory impact analyses supporting the proposed UST regulations. We also supported the development of language for the technical, financial responsibility, and state program approval regulations and provided all comment summary and response support through several iterations of those rulemakings.

Information Collection Requests

After the Paperwork Reduction Act was amended in 1995, ICF International drafted a revised ICR handbook for EPA use. The handbook includes sections on determining whether OMB clearance and an ICR are needed, complying with public notice requirements, filling out standard forms, and performing other new steps. Over the past decade, ICF International has prepared more than 150 ICRs for federal agencies, including generic and survey ICRs.

 

Nuclear Materials Safety and Safeguards Standards for the U.S. NRC

ICF International has provided regulatory support to NRC's Office of Nuclear Materials Safety and Safeguards for several years. For example, ICF International supported an NRC rulemaking to streamline the rules on the medical use of radionuclides. NRC used enhanced public participation to obtain early detailed input from stakeholders. ICF International prepared summaries of four pre-proposal public meetings, which NRC posted on its Web site. We prepared a regulatory impact analysis for the proposed rule, supported three public meetings, and developed a database of public comments and comment summary. We are conducting the regulatory analysis and information collection analysis for the final rule.

Lead Hazard Control in Housing for the U.S. HUD and the U.S. EPA

ICF International support HUD's Office of Lead Hazard Control in developing regulations to reduce lead-based paint hazards in federally assisted and federally owned housing. ICF International assisted HUD in developing the regulatory framework, drafting sections of preambles, conducting the regulatory impact analysis and regulatory flexibility analysis for the proposed and final rulemakings; analyzing public comments on the proposed rule; and preparing NEPA documentation and ICRs. We provided similar support for EPAs lead-based paint programs, including facilitating the involvement of Small Entity Representatives in the rule development process.

Hazardous Waste Regulations for the U.S. EPA

ICF International has supported EPA's hazardous waste program since the early 1980s. We provided rapid-response analyses of legislative reform initiatives and have supported virtually every major hazardous waste regulation for over a decade. We developed issues and options papers, supported Federal Advisory Committees and regulatory development work groups, and prepared a wide array of briefing materials. ICF International helped draft preambles and technical background documents to supported numerous rulemakings. These products include economic impact analyses, Regulatory Flexibility Act analyses, and ICRs. In addition, we summarized comments, helped draft responses, and supported issuance of final rules.

Protected Resources Program Regulations for the NOAA

ICF International assisted NOAA's National Marine Fisheries Service (NMFS) on a variety of regulatory support projects related to the Marine Mammal Protection Act and the Endangered Species Act. Specific tasks included summarizing and responding to over 2,000 pages of public comments received on a proposed rule and helping to rewrite major portions of the final rule in response to those comments. We also drafted numerous briefings and speeches to help NMFS staff explain the rule to various stakeholders.

Guidance on Small Entity Economic Analyses for the U.S. EPA

ICF International supported EPA's development of guidance on performing small-entity economic analyses under the Regulatory Flexibility Act as amended by SBREFA. The guidance provides regulatory staff with direction on applying the latest economic theory including the use of appropriate analytical measures and data sources to regulatory analyses of small businesses, governments, and nonprofit entities. ICF International developed the theoretical background and justification for internally consistent economic impact screening analyses. We described the economic reasoning in support of each measure and discussed how to interpret the results of each measure.

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