From: Notice & Comment | A Blog from the Yale Journal on Regulation and the ABA Section of Administrative Law & Regulatory Practice
by Jim Tozzi
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Professor Rudalevige’s insights provide invaluable guidance to the political leaders of the incumbent Administration and to OIRA managers as OIRA expands its product line from the review of individual regulations to the implementation of a regulatory budget and possibly review of the regulations issued by independent agencies.
In all instances OIRA’s continued existence will require managers who are willing to pay the personal price for imposing discipline throughout the government. As Justice Scalia stated so eloquently, “administrative law is not for sissies”; others call it is a “blood sport”. A contributing phenomenon was identified by a former Director of OMB when he stated: “The bureaucracy is generally resistant, no matter what the hell you’re trying to do.”