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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.
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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 EPAs 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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