Did the Quality of  Life Review Penetrate the Bureaucracy ?

The Quality of Life Review (QLR) was the term given to the first centralized regulatory review process administered by OMB. It predated OIRA review by a decade and was utilized by the Nixon and Ford Administrations.

The Quality of Life Review process differed significantly from the one currently in use by OIRA:

(1) Although its two primary components, OMB review and agency analysis of the benefits and cost of rules are the building blocks of all future Executive Orders on centralized regulatory review, the QLR was conducted by the “budget side” of OMB not a standalone office (OIRA) dedicated exclusively to implementing centralized regulatory review.

(2) OMB did not conduct a de novo review of a proposed rule, instead it conducted an interagency review of proposed rules and served as the referee to reconcile differing views. (In that the QLR was directed primarily toward EPA such a process was viable; it would not be viable  on a government-wide basis).

(3) The QLR lacked transparency because centralized regulatory review was an integral part of the budget process.

(4) The implementing mechanism for the initiation of the QLR was a fifteen line Memorandum from the Director of OMB ; the implementation of the centralized regulatory review process under OIRA supervision is a six page  Executive Order.

Notwithstanding a paucity of written material which describes the inner workings of the QLR some observers conclude that it was very weak if not superficial.

Notwithstanding we Americans nanosecond interest in history, we  offer one piece of critical information to the contrary which was compiled by the legal arm of the environmental bar, the Environmental Law Institute. Please read the first three paragraphs of this article which describes the stature accorded to the centralized regulatory review process of the Ford Administration which was the Quality of Life Review and then decide whether it had more or less penetration than the current regulatory review process.

 

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