1 Mar 2011

The REINS Act:
Would it work as intended?

by Richard Belzer

in Regulatory Policy

House and Senate Republicans have proposed legislation (HR 10, S 299) intending to substantially change federal regulatory practice. The proposed Regulations From the Executive in Need of Scrutiny Act of 2011 (The "REINS Act").

What is the bill supposed to do? What is it likely to do?

21 Jan 2011

Regulatory Review in the Obama Administration:
Clinton and Obama directives compared

by Richard Belzer

in Regulatory Policy

On January 18, President Obama issued an executive order that modifies longstanding principles and procedures for centralized regulatory oversight conducted by by the Office of Management and Budget.

The three tables below provide a side-by-side comparison of the new text with the text of Executive Order 12,866, issued by President Clinton in 1993. To guide readers in making comparisons, text that is underlined is the same in both documents.

Interpreting such texts requires close attention to detail. For this reason, we have color-coded both texts as follows:

GREEN HIGHLIGHT: Directive language (e.g., "shall", "must") with tightly defined verbs (e.g., "identify", "assess", "design", "maximize", "promulgate") often applied to concrete objects (e.g., "net benefits", "duplicative", "burdensome", "least burdensome", "most cost-effective") sometimes comprehensively (e.g., "only").

Objective performance evaluation generally is possible.

YELLOW HIGHLIGHT: Hortatory language (e.g., "should", "may") with loosely defined verbs (e.g., "consider", "promote", "endeavor to provide", "harmonize"), or used to modify directive language ambiguously (e.g., "where feasible and appropriate", "to the extent feasible").

Objective performance evaluation typically is impossible.

Where GREEN text is preceded or followed by YELLOW text, the result is always weaker. 

16 Dec 2010

"Don't Ask, Don't Tell"
Two fatal statistical defects in the DoD surveys

by Richard Belzer

in Information Quality, Regulatory Policy

The Report of the Comprehensive Review of the Issues Associated with a Repeal of 'Don't Ask, Don't Tell' was released by the Department of Defense on November 30, 2010. The Report summarizes and interprets a pair of large-scale surveys of Service members and spouses hat was sponsored by DoD and conducted by WESTAT, a major consulting firm. Immediately thereafter, Congress took up the question whether to repeal the law on which the Department's "Don't Ask, Don't Tell" policy is based.

This post is about the Report's statistical back story, and why the conclusions given in the Report are unreliable as a guide for policy-making -- regardless of whether one prefers to repeal the law, retain the law, or replace it with a more stringent one.