14 Jan 2010
Paperwork Reduction Act
How to improve implementation of the law
by Richard Belzer
in Paperwork Burdens
On October 28, 2009, the Office of Management and Budget solicited comments on its implementation of the Paperwork Reduction Act. The purpose of the PRA is to minimize burdens on the public resulting from the federal government's information requests.
Neutral Source managing editor Richard Belzer submitted comments on his own behalf. These comments eventually will be uploaded by OMB to Regulations.Gov, the Federal government's web portal for all regulatory matters. (Clicking on the link above will reveal a fundamental weakness of the web portal: Unless the agency chooses to include information identifying the name and organizational affiliation of the submitter, there is no way to find any specific comment without opening them all.)
In response to numerous requests, a copy of these comment is posted to the Library.
More...20 Nov 2009
Counting Jobs Created or Saved by the "Stimulus" Bill:
A lesson in information quality
by Richard Belzer
in Information Quality
A scandal has erupted over the federal government's reporting of the number of jobs created or saved by the "stimulus" bill (formally the American Recovery and Reinvestment Act of 2009).
This scandal would have been avoided if the government had complied with the Information Quality Act.
More...23 Mar 2009
The AIG Bonuses, Part 2:
The House tax bill
by Richard Belzer
in Regulatory Economics, Regulatory Policy
Friday we posted an analysis of the economics of bonus payments as part of an employee's compensation. Today we look at H.R. 1586 (Rangel [D-NY]), which was introduced in the House on Wednesday and passed 328-93 on Thursday.
H.R. 1586 is intended to ensure that recipients of these bonuses do not collect them.
More...25 Feb 2009
Regulatory Review in the Obama Administration, Part 3:
Cass Sunstein and his critics
by Richard Belzer
in People & Institutions, Regulatory Policy
Long time University of Chicago Law (and recent Harvard Law) professor Cass Sunstein is expected to be nominated by President Obama to be the new Administrator of the Office of Information and Regulatory Affairs. OIRA is the statutory office within the White House Office of Management and Budget that, among other things, has conducted centralized regulatory oversight on behalf of the president since 1981.
When Susan Dudley was nominated in 2006 to head this office, Neutral Source published an eight-part analysis of her "paper trail," which is summarized here. We undertook this task because her nomination generated controversy from certain activist groups, most notably Public Citizen, and we found significant factual discrepancies between the actual content of this paper trail and her critics claims about it.
We intend to repeat this effort, but Sunstein presents an unusually difficult challenge.
More...24 Feb 2009
Regulatory Review in the Obama Administration, Part 2:
Alive and well, reports to the contrary notwithstanding
by Richard Belzer
in Regulatory Policy
In a February 17 article, Politico reporter Josh Gerstein claims that "[i]n his first weeks in office, President Barack Obama shut down his predecessor’s system for reviewing regulations" and "managed to take all these actions with nary a mention from the White House press corps." Gerstein further claims that this "escaped notice because they were never announced by the White House Press Office and were never placed on the White House web site."
Gerstein's reporting is erroneous.
More...
3 Feb 2009
Regulatory Review in the Obama Administration, Part 1:
Executive Order 13497
by Richard Belzer
in Regulatory Policy
On January 30, President Obama signed Executive Order 13497, which begins the process of changing the way the Office of Management and Budgwet performs centralized review of draft proposed and draft final regulations. In a memorandum to agency heads, the President also announced a plan to produce "a set of recommendations" within 100 days (~ May 14, 2009).
Texts for both documents are provided below.
More...22 Dec 2008
Union Paperwork Burdens
by Richard Belzer
in Paperwork Burdens, Regulatory Policy
In an editorial today, the Wall Street Journal raises concerns about Rep. Hilda Solis' commitment to enforcing information disclosure requirements that apply to unions. Solis has been announced as President-elect Obama's choice to be Secretary of Labor.
Paperwork burdens on the public (including businesses and unions) are governed by the Paperwork Reduction Act. The Office of Management and Budget is statutorily charged with reviewing these burdens before they are imposed to ensure that their "practical utiulity" (i.e., benefits) are commensurate with their "burdens" (i.e., costs).
"Practical utility" often depends on the perspective of the observer. The Journal editorial board says the information has high value to weed out union corruption; union representatives say the reporting requirement is unduly burdensome. Both views are likely colored by policy views concerning what information they believe ought to be publicly disclosed.
Meanwhile, there is a factual dispute concerning how burdensome it actually is for unions to fulfill these paperwork requirements. As it happens, the Paperwork Reduction Act provides potentially useful information on this subject.
More...12 Nov 2008
Petition for Correction to the Office of Management and Budget Concerning the Draft 2008 Report to Congress on the Benefits and Costs of Federal Regulation
by Richard Belzer
in Information Quality
On November 7, 2008, Regulatory Checkbook -- Neutral Sourcve's sister nonprofit organization -- filed a public comment on the Office of Management and Budget's draft 2008 Report to Congress on the Benefits and Costs of Federal Regulation.
This public comment also was submitted as a formal Petition for Correction under OMB's Information Quality Guidelines (PDF). Under those guidelines, influential information OMB disseminates must be substantively and presentionally objective, transparent and reproducible, and provide utility for its intended purposes of informing Congress and the public.
The draft Report does not satisfy these information quality standards.
OMB is obligated by its own guidelines to respond within 60 days (i.e., by January 6, 2009).
More...
25 Sep 2008
Benefits and Costs of Federal Regulation:
2008 draft report published for public comment
by Richard Belzer
in Regulatory Economics
The Office of Management and Budget has published its 2008 draft report to Congress on the benefits and costs of federal reguilation. OMB is required by lawe to publish this report every year.
Public comments are due by Friday, November 7, 2008.
More...17 Feb 2008
When Does a Normal Phenomenon Equal a Crisis?
The declining ranks of nuclear forensics experts
by Richard Belzer
in Regulatory Economics
The Washington Post reports today that the ranks of experts in nuclear weapons forensics is declining, and that the situation requires immediate action by government to avoid a crisis. More...
2 Jan 2008
What Are Judges Worth? Part 2008
Chief Justice Roberts still fails economics but may yet win his case
by Richard Belzer
in Regulatory Economics
A
year ago we posted notes here
and here
on Chief Justice John Roberts' state of the judiciary report for 2007,
in which he bemoaned federal judges' low salaries and warned of a
"constitutional crisis" if salaries were not increased. We were not
competent to offer informed insight on CJ Roberts' legal claim, but we
were able to quickly dispense with his economic arguments. Taking his
own data at face value, we were able to show that his argument lacked
any merit.
The Chief Justice is back with his report
for 2008, and he recycles the same complaints about low judicial
salaries. What's different this year is that the Congressional
Research Service has analyzed the data more carefully than CJ Roberts
did, and found that Roberts' conclusions were not empirically
supported. In this year's report, Roberts' ignores the CRS study,
dropped the economic privation argument he made last year, and adopted
the all-purpose defense used by weak claimants: he divided the cost of
his proposal by the largest imaginable denominator. More...
19 Sep 2007
OMB's Principles for Risk Analysis:
OMB's initial response to the National Academy of Sciences
by Richard Belzer
in Regulatory Policy, Regulatory Science
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...
