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  1. Agency Use of Science in the Rulemaking Process: Proposals for Improving Transparency and Accountability [Download]

    Title: Agency Use of Science in the Rulemaking Process: Proposals for Improving Transparency and Accountability
    Author: Dudley, Susan E.
    Description: Prepared Statement of Susan E. Dudley, The George Washington University Regulatory Studies Center, Hearing on Agency Use of Science in the Rulemaking Process: Proposals for Improving Transparency and Accountability for the Homeland Security and Governmental Affairs Subcommittee on Regulatory Affairs United States Senate on March 9, 2017.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  2. A Review of Regulatory Reform Proposals [Download]

    Title: A Review of Regulatory Reform Proposals
    Author: Dudley, Susan E.
    Description: Prepared Statement of Susan E. Dudley, The George Washington Regulatory Studies Center, Hearing on A Review of Regulatory Reform Proposals before the United States Senate Homeland Security & Government Affairs Committee on September 16, 2015.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  3. Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget [Download]

    Title: Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget
    Author: Dudley, Susan E.
    Description: Prepared Statement of Susan E. Dudley, The George Washington Regulatory Studies Center, Hearing on Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget before the United States Senate Committee on the Budget and Committee on Homeland Security and Governmental Affairs on June 23, 2015.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  4. Examining Practical Solutions to Improve the Federal Regulatory Process [Download]

    Title: Examining Practical Solutions to Improve the Federal Regulatory Process
    Author: Dudley, Susan E.
    Description: Prepared Statement of Susan E. Dudley, The George Washington University Regulatory Studies Center. Hearing on Examining Practical Solutions to Improve the Federal Regulatory Process before the United States Senate Subcommittee on Regulatory Affairs and Federal Management Roundtable Discussion, June 4, 2015.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  5. Recommendations for Improving the Regulatory Process [Download]

    Title: Recommendations for Improving the Regulatory Process
    Author: Dudley, Susan E.
    Description: Prepared Statement of Susan E. Dudley, The George Washington University Regulatory Studies Center, Response to the Senate Homeland Security and Governmental Affairs Committee's Letter Requesting Input on its Regulatory Improvement Effort on May 4, 2015.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  6. OMB’s Draft 2013 Report to Congress on Regulatory Costs and Benefits has Limitations [Download]

    Title: OMB’s Draft 2013 Report to Congress on Regulatory Costs and Benefits has Limitations
    Author: Dudley, Susan E.
    Description: The benefits and costs of regulations, individually and in the aggregate, are notoriously hard to measure. In an attempt to measure the size and scope of regulation, the Office of Management and Budget (OMB) each year submits to Congress an accounting statement and associated report providing estimates of the total annual benefits and costs of federal regulations. According to a new GW Regulatory Studies Center comment submitted to OMB, OMB’s Draft 2013 Report to Congress on the Benefits and Costs of Federal Regulations (the Report) probably offers one of the most comprehensive estimates available on the expected benefits and net benefits (benefits minus costs) of federal regulation; but, as OMB acknowledges, it has limitations. The benefits reported both for fiscal year 2012 and over the last decade are dominated by EPA regulations that reduce fine particles (PM2.5) either directly or incidentally. OMB provides a good qualitative presentation of the many uncertainties surrounding the PM2.5 benefits, but it should go further. It should reveal to the public the effect of these uncertainties on the range of plausible benefits derived from regulations.
    Keywords: Regulation, Commentaries, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 03/31/2018
  7. What are Regulatory Proxies Measuring? [Download]

    Title: What are Regulatory Proxies Measuring?
    Author: Pack, Terry
    Description: Without reliable measures of regulatory activity, attempts to understand regulations’ effect on the economy will be hindered, so the lack of correlation between the variables currently being used in the economic literature is troubling. The fact that none of them are closely correlated perhaps suggests that each variable captures a different facet of regulation, or perhaps our simple correlations do not adequately capture relationships among them. For example, one might expect CFR pages or constraints to follow the Regulators’ Budget or Federal Register pages with a lag (and our correlation measures include no lag). Nevertheless, these results suggest that further research is needed if we are to understand the effects of regulation on economic growth.
    Keywords: Regulation, Commentaries, Federal government, Regulatory studies, Regulatory policy, Public policy
    Date Uploaded: 03/31/2018
  8. Toxic Sand? OSHA’s Challenge in Regulating Crystalline Silica [Download]

    Title: Toxic Sand? OSHA’s Challenge in Regulating Crystalline Silica
    Author: Dudley, Susan E.
    Description: The Occupational Safety and Health Administration’s new proposed regulation to reduce workplace exposure to crystalline silica has been almost 40 years in the making. Also called silicon dioxide (or, more commonly, quartz), crystalline silica occurs abundantly in sand, soil, and rock. OSHA first established a maximum permissible exposure level for crystalline silica in 1970 by adopting a consensus industry standard. Unfortunately, the form of that standard was obsolete by the time it was adopted, and OSHA issued an advance notice of proposed rulemaking to modify it in 1974, but took no further action. Then, in 1994 OSHA identified crystalline silica as one of a few top priority safety and health hazards, and, two years later, the International Agency for Research on Cancer concluded that “crystalline silica inhaled in the form of quartz or cristobalite from occupational sources is carcinogenic to humans.” In 1998, OSHA listed regulation of silica on its semi-annual agenda of upcoming regulatory actions and, by the fall of 1999, set itself a deadline of June 2000 for issuing a proposed rule. In 2002, OSHA revised the deadline to November 2003 and listed the proposed rule as one of its top priorities. This deadline kept slipping, however, until February 2011, when OSHA sent a draft of the rule to the Office of Information and Regulatory Affairs for interagency review. This review took an unusually-long two-and-a-half years to complete, but culminated in OSHA publishing a proposal on its website on August 23, 2013.
    Keywords: Commentaries, Federal government, Regulation, Regulatory studies, Regulatory policy, Public policy
    Date Uploaded: 03/31/2018
  9. The Social Cost of Foregoing Public Participation in the SCC [Download]

    Title: The Social Cost of Foregoing Public Participation in the SCC
    Author: Dudley, Susan E.
    Description: The Department of Energy (“DOE”) is seeking public comment on whether it was appropriate to rely on an estimate of the “social cost of carbon” (“SCC”) in a final rulemaking without undergoing public comment. When DOE published a proposed rule to set energy efficiency standards for microwave ovens in February 2012, it sought public comment on its analysis of the regulation’s contribution toward reducing climate change, using an SCC of $25.6/metric ton. However, in June 2013, DOE defended its final rule with a much higher SCC value of $41.1/metric ton, increasing the anticipated net benefits of the rule by $438 million. An Interagency Working Group on the Social Cost of Carbon had developed this new SCC, and presented it in a “Technical Support Document” (SCC-TSD) as a fait accompli to the public in May. Our comment to DOE agrees that the SCC is conceptually the right way for agencies to organize their analyses of climate impacts and coordinate across different agencies engaged in climate policy. However, the influential nature of the SCC value for a variety of future policies, as well as the difficulties and uncertainties of calculating the SCC, demand conscientious attention— including public comment and peer review—to the task of getting it right.
    Keywords: Regulation, Federal government, Commentaries, Regulatory studies, Regulatory policy, Public policy
    Date Uploaded: 03/31/2018
  10. Social Media in Rulemaking Workshop [Download]

    Title: Social Media in Rulemaking Workshop
    Author: Dudley, Susan E.
    Description: Federal agencies are increasingly turning to the Internet when conducting rulemaking. Regulations.gov, which originated as a central forum for agencies to post regulatory dockets and receive public comments, has offered expanding capabilities over its 10-year history. Nevertheless, according to a recent draft report prepared for the Administrative Conference of the United States, “for the most part, social media are used to get the word out about a rulemaking, but not as a mechanism through which the rulemaking is actually conducted.”
    Keywords: Regulation, Federal government, Commentaries, Regulatory policy, Regulatory studies, Public policy
    Date Uploaded: 03/31/2018