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.

19 Mar 2009

The AIG Bonuses:
The economics of rewarding performance -- and circumventing regulatory limits

by Richard Belzer

in Regulatory Economics, Regulatory Policy

Is there anything new -- and objective rather that opinionated -- that can be said about the AIG bonuses story?

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.

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.

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.

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).

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.

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...

6 Jul 2007

To Beer or Not to Beer?
A complex governmental solution to a simple economic problem

by Richard Belzer

in Regulatory Economics, Regulatory Policy

The Indiana legislature has enacted a law making it a crime to recycle beer kegs. Apparently, their value as scrap metal exceeds the deposits beer distributors charge, so a lot of empty kegs wind up being sold to scrap metal dealers.

Solving this problem through governmental action was a lot more complicated than solving it through markets. And it might not work. More...

22 Jun 2007

What Is a Firm?
Economics reasoning in shareholder securities fraud suits

by Richard Belzer

in Regulatory Economics

The U.S. Supreme Court decided on June 21 that under federal law governing shareholder suits alleging securities fraud (Tellabs v. Makor Issues and Rights), "an inference of scienter must be more than merely plausible or reasonable—it must be cogent and at least as compelling as any opposing inference of non fraudulent intent." Newspaper commentary on the case correctly suggests that this will make shareholder suits more difficult. However, other aspects of economic reasoning in these stories has been woefully lacking.

Exhibit A is Stephen Labaton's Page One article in the New York Times. More...