19 Sep 2007
OMB's Principles for Risk Analysis:
OMB's initial response to the National Academy of Sciences
by Richard Belzer
in Regulatory Science, Regulatory Policy
Today the Office of Management and Budget issued a memorandum to agency heads directing them to adhere to certain principles of risk analysis. The memorandum is OMB's initial response to the report of a National Research Council panel that OMB asked to review a 2006 proposed bulletin on risk assessment. That report called the proposed text "fundamentally flawed" and gave seven recommendations, one of which was that it be withdrawn.
A fair reading of the new memorandum is that OMB followed this specific recommendation. More...
27 Jul 2007
Who Pays the Cost of Regulation?
Insights from corporate income tax incidence
by Richard Belzer
in Regulatory Economics
Regulation is widely understood as a tax on the activity or person being regulated. Where these activities repair genuine market failures, benefits from regulation may result. If there are benefits from, say, automobile safety regulation, one would expect the beneficiaries to be persons who otherwise would have been killed or injured at the pre-regulatory safety level.
But what about the costs of regulation? Who bears them? More...
11 May 2007
Government-wide Information Quality Guidelines:
Does journal peer review achieve "adequate" objectivity?
by Richard Belzer
in Glossary, Information Quality, Peer Review
Federal guidelines require information disseminated by federal agencies to satisfy a few broad criteria, one of which is objectivity. These guidelines give a "rebuttable presumption" to scientific information published in scholarly journals.
- Do all scholarly journals transmit this rebuttable presumption of objectivity? What about scholarly journals that also have an advocacy mission?
- What is the burden of proof for mounting a successful rebuttal?
More...
9 May 2007
Federal Agency Guidance Documents:
What's "significant"?
by Richard Belzer
in Regulatory Policy
OMB has new procedures for agencies to follow in making significant guidance documents transparent.
We posted an extensive discussion on OMB's Bulletin on Good Guidance Practices, and recently OMB issued an implementation memorandum. Yesterday we commented on the first task facing federal regulatory agencies: assembling and publishing online lists of guidance documents.
Today we address another fundamental question: What constitutes a "significant" guidance document, an d how is this determination made? More...
8 May 2007
Federal Agency Guidance Documents:
Building the inventory
by Richard Belzer
in Regulatory Policy
Executive Order 13422 and OMB's Bulletin on Good Guidance Practices will lead to major changes in the way federal agencies issue guidance.
The first step for each agency is to develop and publish inventories of their significant guidance documents. The deadlines for agency compliance are July 24, 2007 (for significant guidance documents issued on or after January 25, 2007) and August 23, 2007 (for all significant guidance documents). More...
7 May 2007
The New OMB Regulatory Review Procedures:
A primer on implementation
by Richard Belzer
in Regulatory Policy
On April 25 OMB issued guidance to agencies concerning the implementation of Executive Order 13422. More...
20 Feb 2007
Markets Work
What happens when governments suppress market forces
by Richard Belzer
in Legislation, Regulatory Economics, Regulatory Policy
Today's news brings a pair of interesting (and foreboding) lessons in what happens when government tries to suppress markets.
In Iran, government subsidies make the price of gasoline just 40 cents per gallon. In Florida, the state has decided to subsidize the cost of property insurance.
In Iran, there is massive overconsumption of energy that threatens both the economy and the polity. Its authoritarian, theocratic government is unwilling to endure the public reaction that would result from restoring market prices for energy.
In Florida, property owners in harm's way will overinsure and not bother taking otherwise cost-effective measures to reduce their losses from future hurricanes. When the hurricanes come, their losses will be covered by surcharges on other property owners (especially those out of harm's way) and taxpayers.
More...14 Feb 2007
Executive Order 13422, Part 5a
The House subcommittee oversight hearings
by Richard Belzer
in Regulatory Policy
Today we start a series summarizing the testimony from all eight witnesses who appeared yesterday before two separate House oversight subcommittees. More...
13 Feb 2007
Executive Order 13422, Part 4b
An update on today's congressional hearings
by Richard Belzer
in Regulatory Policy
The previously scheduled joint subcommittee hearing has been split into a back-to-back marathon double hearing. See our event record for links to witness testimony.
The full witness list is below.
| Committee | Administration Witnesses |
Majority Witnesses |
Minority Witnesses |
| Science |
Sally Katzen David Vladeck Rick Melberth |
William Kovacs | |
| Judicary | Steven D. Aitken |
Curtis W. Copeland Sally Katzen Peter L. Strauss |
Paul R. Noe |
More...
8 Feb 2007
Executive Order 13422, Part 4
Partisan opposition erupts
by Richard Belzer
in Regulatory Policy
We thought we'd finished discussing Executive order 13422, President Bush's recent amendment to the Clinton-era Executive order on centralized regulatory review.
On Tuesday, February 13, a pair of House subcommittees will hold a hearing to criticize the Executive order.
More...6 Feb 2007
Good Guidance Practices
Definitions, requirements, and consequences
by Richard Belzer
in Regulatory Policy
On January 18, the Office of Management and Budget issued final
government-wide guidance on the issuance of guidance in lieu of
rulemaking. OMB's Bulletin for Agency Good Guidance Practices is
rich with content. Today we begin a series intended to educate the
public about this Bulletin and its implications for regulatory policy
and process.
More...
5 Feb 2007
Market Success, Regulatory Failure
Lessons for regulatory policy from the market for blind-side offensive tackles in the NFL
by Richard Belzer
in Information Quality, Regulatory Policy
Michael Rosen reviews The Blind Side, a book on college and pro football by Michael Lewis. Rosen uncovers the reason why blind-side (usually left) offensive tackles are so important in football, and why they are so well paid.
They are valuable because they protect teams' franchise players, their (usually right-handed) quarterbacks from sacks, fumbles, and most importantly, injury. They are paid well because there is an unregulated market for their services, and unregulated markets generally work very well.
More...4 Feb 2007
Executive Order 13422, Coda
Whither the vice president?
by Richard Belzer
in People & Institutions, Regulatory Policy
Press accounts concerning the changes President Bush has made to White House regulatory review procedures show that reactions have been largely partisan, and thus predictable and uninformative. We posted a three-part series analyzing the text of Executive order 13422 found here, here, and here.
One important question has not arisen in these press accounts, but should have. Historically, it has been the vice president who has been given the authority to decide matters of regulatory controversy within the Executive branch. But the veep isn't mentioned in Executive order 13422. Where did he go? More...
2 Feb 2007
Executive Order 13422, Part 3
The skinny on the new regulatory planning provisions
by Richard Belzer
in Regulatory Policy
Today we provide our third and last expected installment on Executive order 13422. In Part 1 we discussed the expansion of centralized regulatory review to guidance. We explained why the OMB staff historically has been hamstrung by this exclusion, and why regulatory agencies often prefer to issue guidance to circumvent both OMB review and the Administrative Procedure Act.
In Part 2, we addressed claims made by opponents of OMB oversight that the text on market failure represented a change in OMB's review criteria. We showed that the content of the new text wasn't itself new because market failure has been an explicit part of the review criteria since 1981.
In today's Part 3, we address the third new provision: the regulatory planning provisions in sections 4 and 6.
More...1 Feb 2007
Executive Order 13422, Part 2
The kerfuffle over 'market failure'
by Richard Belzer
in Regulatory Economics, Regulatory Policy
President Bush's Executive order 13422 changed the domain of centralized regulatory oversight, its governing philosophy, and certain procedures related to regulatory planning. Yesterday we posted on the changed domain -- the inclusion of signifcant guidance documents within the centralized oversight apparatus. Today's installment concerns the change in regulatory philosophy.
More...
