The George Washington University Regulatory Studies Center improves regulatory policy
through research, education, and outreach. As part of its mission, the Center conducts careful and
independent analyses to assess rulemaking proposals from the perspective of the public interest.
This comment on the Office of Management and Budget’s interim guidance implementing
Executive Order 13771 does not represent the views of any particular affected party or special
interest, but is designed to improve both regulatory processes and regulatory analysis. On January 31, President Trump signed Executive Order 13771, “Reducing Regulation and
Controlling Regulatory Costs,” which instructs agencies to identify two regulations for removal
for each new rule they propose and to limit incremental regulatory costs to $0 in fiscal year (FY)