We received a number of comments on our post on Notice and Comment.
One comment that was shared by a number of commentators was that the formulation and implementation of centralized regulatory review as reported in the press was at times not-transparent and overly forceful.
The aforementioned statement is a fair one. But in itself is a statement as to the need for the many regulatory practitioners who believe that centralized regulatory review is an entitlement and who have a nanosecond interest in history to spend some time learning of its maturation. Starting from its initial conception during the Johnson Administration continuing through the Reagan Administration there was outright hostility in some areas of the government to the idea of centralized regulatory review. Consequently it became very obvious if one were going to launch the Good Ship OIRA it was not going to happen by holding hands and singing kumbaya.