[Editor’s Note: This is Jim Tozzi’s review of Eloise Pasachoff, The President’s Budget as a Source of Agency Policy Control, 125 Yale Law Journal 2182 (2016), which originally appeared here. Jim Tozzi served as a career regulatory official in five consecutive Administrations and was instrumental in the establishment of centralized regulatory review.]
Centralized regulatory review began on the “budget side” of OMB in the form of the Quality of Life Review. From the onset probably the single biggest opposition to OMB assuming its new role were career budget examiners who stated regulatory review was very political and it would eventually set the stage for an intrusive oversight of the budget process.
Well it took forty five years but they were correct as witnessed by the recommendations in the following article. Consequently the author of the following article is to be complimented not only for educating the public of the very important and far reaching impacts of the “budget side” of OMB but also for setting the stage for disclosing an observation that few scholars of centralized regulatory review appreciate.