Public Participation

In response to the Sensible Regulation initiative, I am writing to inform you of a recommendation we have made to the White House office in charge of regulatory oversight of federal agencies, the Office of Information and Regulatory Affairs (OIRA).  Although I was instrumental in establishing  the  office, I am no longer employed by the organization. Most recently I was an active participant in the establishment of  A Forum for Venting Key Submissions to OIRA

We have proposed a mechanism for controlling the total cost of regulations, a regulatory budget, and it is described in detail in a post on the website of the Center for Regulatory Effectiveness (CRE)  at https://www.thecre.com/forum8/?p=8371

 A Suggestion: Implement a Prototype Regulatory Budget in One Agency

Some fifty years ago when the Quality of Life Review , the precursor to centralized regulatory review,  was initiated EPA was identified as the key agency to which the new procedures would apply. EPA responded by establishing an excellent analytical capability which was central to the establishment of centralized regulatory review as a key component of the administrative state. The aforementioned analytical capability continues to this very day and  would make an invaluable contribution to the development of a regulatory budget. Consequently  why not capitalize on this invaluable asset by  initiating work immediately on a prototype regulatory budget for EPA which would provide a basis for an informed public review of the subject?

A key feature of the Prototype Regulatory Budget would be that its components would be ranked by two alternative ranking systems:

•  Conventional benefit-cost analyses
•  A distributional weighting of benefits     

For those readers interested in understanding the considerably broader implications of the impact of implementing a regulatory budget we have provided a copy of an article we published several years ago. The said article  demonstrates that conventional benefit-cost analysis will continue to play an important– but a lesser— role in federal decision-making with the implementation of a regulatory budget.

We have worked strenuously to provide the relevant background material to participate in this initiative in one concise location at https://www.thecre.com/forum8/?p=8371. Consequently we would appreciate your participating in the implementation of a regulatory budget by sharing this email with regulators in the Executive branch as well as with your colleagues in the regulated industries.