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  1. Examining How Small Businesses Confront and Shape Regulations [Download]

    Title: Examining How Small Businesses Confront and Shape Regulations
    Author: Miller, Sofie E.
    Description: Prepared Statement of Sofie E. Miller & Daniel R. Pérez, The George Washington University Regulatory Studies Center, Hearing on Examining How Small Businesses Confront and Shape Regulations Before the Small Business & Entrepreneurship Committee United States Senate on March 29, 2017.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory studies, Public policy, Regulatory policy
    Date Uploaded: 05/05/2018
  2. Safety Standard Addressing Blade-Contact Injuries on Table Saws [Download]

    Title: Safety Standard Addressing Blade-Contact Injuries on Table Saws
    Author: Miller, Sofie E.
    Description: Prepared Statement of Sofie E. Miller & Jacob Yarborough, The George Washington University Regulatory Studies Center, Hearing on Safety Standard Addressing Blade-Contact Injuries on Table Saws Before the United States Consumer Product Safety Commission on August 9, 2017.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  3. The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy [Download]

    Title: The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy
    Author: Miller, Sofie E.
    Description: Prepared Statement of Sofie E. Miller, Senior Policy Analyst, The George Washington University Regulatory Studies Center, Hearing on The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy before the United States House of Representatives Judiciary Committee Task Force on Executive Overreach on May 24, 2016.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  4. Home Appliance Energy Efficiency Standards under the Department of Energy–Stakeholder Perspectives [Download]

    Title: Home Appliance Energy Efficiency Standards under the Department of Energy–Stakeholder Perspectives
    Author: Miller, Sofie E.
    Description: Prepared Statement of Sofie E. Miller, The George Washington University Regulatory Studies Center, Hearing on Home Appliance Energy Efficiency Standards under the Department of Energy–Stakeholder Perspectives before the United States Senate June 10, 2016.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  5. Oversight of the Renewable Fuel Standard [Download]

    Title: Oversight of the Renewable Fuel Standard
    Author: Miller, Sofie E.
    Description: Prepared Statement by Sofie E. Miller, Senior Policy Analyst, The George Washington University Regulatory Studies Center, Hearing on Oversight of the Renewable Fuel Standard before the Environment and Public Works Committee on February 24, 2016.
    Keywords: Regulation, Testimony, Testimonies, Federal government, Regulatory policy, Public policy, Regulatory studies
    Date Uploaded: 05/05/2018
  6. President Nominates Howard Shelanski to be OIRA Administrator [Download]

    Title: President Nominates Howard Shelanski to be OIRA Administrator
    Author: Miller, Sofie E.
    Description: Last week, President Obama nominated Federal Trade Commission (FTC) Chief Economist Howard Shelanski to be the next Administrator of the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB). If confirmed by the Senate, Shelanski would fill the position vacated by Cass Sunstein, who returned to Harvard’s law faculty in August 2012. Boris Bershteyn, former OMB General Counsel, had held the position in an acting capacity until his departure from OMB last month. Career Deputy Administrator, Dominic Mancini is currently Acting Administrator.
    Keywords: Regulation, Commentaries, Federal government, Regulatory policy, Regulatory studies, Public policy
    Date Uploaded: 03/31/2018
  7. 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
  8. Reducing the Regulatory Burden: Recommendations for FDA’s Proposed Food Safety Rule [Download]

    Title: Reducing the Regulatory Burden: Recommendations for FDA’s Proposed Food Safety Rule
    Author: West, Cassidy B.
    Description: In January, the Food and Drug Administration (FDA) published a proposed rule, Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, establishing minimum standards for the safe growing, harvesting, packing, and holding of produce. Our examination of the proposed rule and supporting analysis reveals that the proposal does not meet the statutory and executive requirements nor does it consider unintended consequences that may result from the proposed safety standards; and the estimates used to support the benefits of the rule are based on unreliable data.
    Keywords: Regulation, Commentaries, Federal government, Regulatory policy, Public policy, Regulatory studies
    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. Much-anticipated CO2 Emissions Rule Renders Zero Benefits or Costs in Agency Analysis [Download]

    Title: Much-anticipated CO2 Emissions Rule Renders Zero Benefits or Costs in Agency Analysis
    Author: Miller, Sofie E.
    Description: On September 20th, the Environmental Protection Agency released a much-anticipated proposed rule that would limit the emissions of CO2 by new coal- and natural gas-fired power plants, or electric utility generating units (EGUs). This proposal is one of many regulatory actions being undertaken by the Obama administration to curb carbon emissions, and is the first uniform federal limit on CO2 production for new power plants. Carbon emissions from existing power plants are currently regulated by state implementation of federal guidelines, and next year EPA will propose federal standards for existing plants. Interestingly enough, EPA’s analysis suggests that the proposed rule doesn’t exert any meaningful requirement on emissions from new power plants: “Because these [proposed] standards are in line with current industry investment patterns, these standards are not expected to have notable costs and are not projected to impact electricity prices or reliability.” In other words, EPA is projecting that, even without the proposed standards, emissions would have fallen by a comparable amount due to shifts from investment in coal plants to natural gas-fired plants, which have lower CO2 emissions. EPA makes the same point even more clearly in its regulatory impact analysis (RIA): “the proposed EGU New Source GHG [greenhouse gas] Standards are not expected to change GHG emissions for newly constructed EGUs, and are anticipated to yield no monetized benefits and impose negligible costs, economic impacts, or energy impacts on the electricity sector or society.” According to the agency’s analysis, EPA presumes that any costs incurred by power plants will be at least partially recovered through sale of captured carbon.
    Keywords: Regulation, Commentaries, Federal government, Public policy, Regulatory policy, Regulatory studies
    Date Uploaded: 03/31/2018