OIRA continues to set an exemplary example on keeping the public aware of its regulatory review function. In particular it disclosed in considerable detail the substance of a meeting it had on electric utility emission standards dealing with greenhouse gases.
Accolades to GE for putting on the record its detailed comments. See this document.
The above meeting is in keeping with Judge Wald’s decision in Sierra Club v. Costle in which she concluded:
Under our system of government, the very legitimacy of general policymaking performed by unelected administrators depends in no small part upon the openness, accessibility, and amenability of these officials to the needs and ideas of the public from whom their ultimate authority derives, and upon whom their commands must fall. As judges we are insulated from these pressures because of the nature of the judicial process in which we participate; but we must refrain from the easy temptation to look askance at all face-to-face lobbying efforts, regardless of the forum in which they occur, merely because we see them as inappropriate in the judicial context.
OIRA has been described as the cockpit of the regulatory state; the aircraft will continue to fly in blue skies if it remains a transparent organization.
