Comment on OMB’s Report to Congress on the Benefits and Costs of Federal Regulation

From: Regulatory Studies Center/George Washington University

By Susan E. Dudley, Brian F. Mannix, & Sofie E. Miller

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The George Washington University Regulatory Studies Center works to improve regulatory policy through research, education, and outreach. As part of its mission, the Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on the Office of Management and Budget’s Draft 2014 Report to Congress offers suggestions for improving the information value of the Report, and does not represent the views of any particular affected party or special interest.


Pursuant to the Regulatory Right-to-Know Act,[1] the Office of Management and Budget (OMB) submits to Congress each year an accounting statement and associated report providing estimates of the total annual benefits and costs of federal regulations; an analysis of impacts of Federal regulation on State, local, and tribal government, small business, wages, and economic growth; and recommendations for reform.[2]

OMB’s Draft 2014 Report to Congress on the Benefits and Costs of Federal Regulations (the Report) provides the Congress and the public with valuable information both on estimates of the effects of major executive branch regulations and also on OMB’s focus and priorities as it reviews agency regulations. This comment addresses several topics covered in the Report: 1) implementation of President Obama’s retrospective review initiative, 2) aggregate benefits and costs, and issues associated with their estimation, 3) effects of regulations issued by independent regulatory agencies, 4) presentation of trends in regulatory benefits and costs, 5) distributional impacts, and 6) employment effects.

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