October 16, 2015

A Program to Develop a Nationwide Constituency for OIRA

A Nationwide Constituency for OIRA Will Allow It to Discharge Its Statutory Obligation To Free All Citizens From Onerous Regulations  On a Continual Basis Without Intermittent Disruptions From a Vocal Few


1.  OIRA, the Office of Information and Regulatory Affairs located in the White House Office of Management and Budget, is in need of  a National constituency if it is going to fend off proposals to limit its scope of operation. OIRA’s staff has been reduced fifty percent since the date of its establishment in 1980. OIRA is frequently presented as a villain in both press and academic articles because it is performing a very difficult task—saying no to regulatory proposals, however well intended, which fail to meet tests of economic efficiency and effectiveness. A national constituency will provide a counter balance to OIRA’s detractors.

2. A national constituency can not be achieved by a top-down approach from DC; what is  needed a grass roots movement aimed at getting support from the millennials through a student writing competition.  Here is what happens when a millennial is not provided with all the facts.

3. The papers developed through the student writing contest will be incorporated into the OIRA Teaching module which  presently is being provided at no cost to schools of law, economics, public policy, public administration and political science. We expect a significant spillover effect into regulators resulting  from a barrage of student papers reinforced by roundtables at the local level. These local roundtables could be  video taped and transmitted to a large number of university departments of law, political science, public policy and public administration

4. The student writing competition will focus on four issues . Timely implementation of any of the four issues  would provide a basis for an informed response to observers who want OIRA to both obtain  additional resources and expand its product line.

A case in point involves the OIRA implementation of Data Quality Act (DQA) because it (1) provides a new product line  for  OIRA and  (2) its implementation requires additional resources. The Department of Justice has informed the court that OIRA has the final say on enforcing the Data Quality Act and soon the Administrative Conference will address the need to have a correction process in place for federal data bases; these two actions taken by leading federal agencies set the stage for an escalation in the use of the Data(Information Quality) Act.

The DQA should be the centerpiece for a sound science agenda for the incoming administration because it establishes standards for scientific data used to develop federal regulations.  Presently OIRA is constrained because it lacks a constituency to counteract parties who oppose the implementation of such a sound  science agenda and because of draconian reductions in its staff level.

Please note that the DQA is one of the rare statutes that vests the complete authority for implementing the Act with OIRA. Consequently if OIRA’s national constituency were to convince OIRA to compel its attorney’s in the Department of Justice to argue in court that the DQA is judicially reviewable we would be taking a giant step forward in making regulatory actions be science based.

More on the Data Quality Act.

Want to get involved? Want to sponsor a regional meeting with students? Please contact the Center for Regulatory Effectiveness.

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