Option # 3: An Initial Approach to Addressing Income Inequality in Federal Rulemaking

Two days after the election CRE published a paper titled: “Questions to Nominees for the Administrator of OIRA” which was distributed widely to affected parties.

Option #2 received considerable attention in that it deals with OIRA assuming a proactive role in addressing existential threats.

Option #3 at least until now, received considerably less attention. The thrust of this option is the need for OIRA to develop a multi-year, multi-agency regulatory program which is reviewed by the public, the Congress and stakeholders.

Option #3 also provides a mechanism to address income inequality in rulemaking while Social Welfare Functions are being sharpened for widespread adoption throughout the federal government. Basically one could start with all available NPRM’s and rank order them in their descending level of net benefits. When a regulation does not pass the national efficiency test of positive net benefits it could be subjected to a qualitative comparison of its merits relative to the marginal regulation in the aforementioned list.

With further analysis additional decision rules could be formulated. Notwithstanding its shortcomings it might have advantages over weighting for the issuance of more explicit guidance on Social Welfare Functions.

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