OIRA’s Lineage and Enforcement Responsibilities 

Editor’s Note:  This post presented on  Yale-ABA Notice and Comment

Professor Andrew Rudalevige of Bowdoin College has written two articles on the creation of OIRA. One just published in the 2018 Winter Edition of National Affairs (Rudalevige # 2) and the other an earlier and more detailed presentation published by the Midwest Political Science Association.

Professor Rudalevige concludes:

“Presidential authority is a key starting point for managing the executive branch. But as OIRA’s history should make clear, it is not the only important factor. Regulatory review did not instantly spring into being when Reagan signed his executive order; it came about only after more than a decade of effort prior to the Reagan administration, and it developed only because Reagan and his team invested in its maturation.

Vanity Abounds in the Absence of P & L Responsibilities

Editor’s Note: CRE in its role as a regulatory watchdog is in near daily contact with federal regulators. In this capacity we learn of their observations and concerns  and on occasion share them with our readers.


In the pursuit of balanced regulation federal regulators are exposed to a wide range of personal traits in those being regulated.  However many agree that vanity abounds in the presence of those employees who are free from  P & L responsibilities or P & L concerns.

N. B. Herman Melville: “I have come to regard this matter of Fame as the most transparent of all vanities”.

EPA’s 2011 Inspector General Report on Greenhouse Gases: The Gift that Keeps Giving

CRE believes that there is no report on the use of the Data Quality Act that exceeds the analytical strength of the one prepared by EPA’s Inspector General titled: “Procedural Review of EPA’s Greenhouse Gases Endangerment Finding Data Quality Processes” in 2011.

The EPA IG report is now central to a defense for a possible forthcoming revised statement of EPA’s position on this matter.

The report is encyclopedic in terms of its detailed explanation of the DQA and is somewhat unique in that it lays out a game plan for invoking the HISA (Highly Influential Scientific Assessment) paradigm for fulfilling the peer review requirements of the Act.

Contributions: Center for Regulatory Effectiveness

Over the past half century CRE personnel have been instrumental in the construction of, or  participation in, the following landmarks within the Administrative state: