Archive for April, 2014
Retrospective Review: Do Agencies’ Proposals Measure Up?
From: George Washington University/Regulatory Studes Center–Regulatory Commentary
Sofie E. Miller, Policy Analyst
As part of our continuing focus on retrospective review of regulations, the GW Regulatory Studies Center is commencing a new initiative, the Retrospective Review Comment Project. Through this project, we will examine significant proposed regulations to assess whether they include plans for conducting retrospective review, and submit comments to provide suggestions on how best to incorporate plans for retrospective review when new regulations are issued. Our first retrospective review comment is on the National Labor Relations Board’s Representation Case Procedures proposal.
Analyzing the Job Impacts of Regulation
From: RegBlog/Penn Program on Regulation
Competing and extreme claims about the relationship between regulation and jobs pervade political debate in Washington, D.C. Some politicians claim that regulations kill significant numbers of jobs by increasing the cost of production, while others claim that regulations create jobs by creating new products and new opportunities for investment. Ultimately this heated debate provides little insight into what is, at root, an important empirical question in an era of bleak economic conditions: Do regulations actually kill jobs?
(UK) HM Treasury Guidance on Appraisal of Government Programs
Editor’s Note: CRE in engaged in a long-term project analyzing the centralized regulatory review function in Brazil and the UK. As part of this project, CRE highlights HM Treasury’s just-released binding guidance document, The Green Book: Appraisal and Evaluation in Central Government along with its associated business model guidance and templates and its supplementary guidance for specialized purposes, such as assert valuation, discounting and risk. Below is HM Treasury’s overview of The Green Book followed by a brief excerpt from its Preface.
From: HM Treasury
GAO Spotlights MSHA’s Data Selection Decision
Editor’s Note: The GAO Mine Safety Report GAO-14-345, “Basis for Proposed Exposure Limit on Respirable Coal Mine Dust and Possible Approaches for Lowering Dust Levels,” found here, assesses MSHA’s decision to “not use NIOSH’s surveillance data as the basis for its proposed new coal mine dust limit…” and instead base their proposal on other available data. GAO’s assessment of the agency’s data selection decision indicates that their auditing standards are consistent with OIRA’s government-wide data quality requirements.
Below is are two excerpts from the GAO report.
Measuring the Impact of Public Comments
Editor’s Note: Analyses seeking to understand the effect of public comments need to analyze the substance of the comments submitted.
From: George Washington University/Regulatory Studies Center
For decades, a central question in rulemaking has been the extent to which public comments on proposed rules affect the substance of agency regulations. On the one hand, the notice and comment process has been likened to Kabuki theater. On the other hand, researchers have discovered that, under certain circumstances, comments can have substantial effects on final rules.