30 Jul 2011
'Food Deserts' or Mirages?
How many people live there?
by Richard Belzer
in Regulatory Science, Information Quality
Sometimes an urban "food deserts" is in fact a mirage because of a significant error in the data or a cramped, unrealistic definition of "low access" that disregards nearby stores in adjacent census tracts.
Only 7 census tracts in Washington, DC are identified as "food deserts." In one case, the reason is not a lack of access so much as the government's cramped definition of an acceptable grocery store. In one other case, the reason is the government's definition disregards large grocery stores in adjacent census tracts that lie within one mile of where people actually live. For the remaining five census tracts, no large grocery stores appear to be nearby under any reasonable definition of the term. But these census tracts are predominantly industrial.
More...29 Jul 2011
'Food Deserts' or Mirages?
A second look at the data
by Richard Belzer
in Information Quality, Regulatory Economics, Regulatory Science
Yesterday's post on the federal government's new program to eradicate "food deserts" provided an obvious example in which the database yields nonsensical results. A large US Army installation, one with its own grocery store, no unemployment, and essentially no poverty, nevertheless appeared to meet all of the government's (arbitrary) criteria for inclusion.
A closer look shows that there is yet another reason why this particular "food desert" is a mirage. Soldiers who live within this census tract actually do live within one mile of a second, large grocery store--albeit one that is in an adjacent census tract.
More...28 Jul 2011
'Food Deserts' or Mirages?
A look at the data
by Richard Belzer
in Information Quality, Regulatory Economics, Regulatory Policy, Regulatory Science
One of the latest trends in federal government food policy is the eradication of "food deserts" -- places where it is said to be difficult to find fresh produce. The Economic Research Service of the US Department of Agriculture has created an interactive map to help you learn whether you live in a "food desert".
The data are interesting, but perhaps not for the intended reason.
More...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?
More...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.
More...
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...13 Jan 2010
Sin Taxes:
Maryland's proposed 10-cent per drink alcohol tax
by Richard Belzer
in Regulatory Economics
Sin taxes are always popular with legislators. People volunteer to pay them, and volunteers garner little public sympathy.
Maryland legislators are proposing to levy a new tax of ten cents per eight ounces of alcoholic beverage sold in the State. A news story today shows how proponents of sin taxes tend to also be in favor of sin.
More...9 Aug 2009
Market 'Failure' in the Wine Business:
The case of 'Wines 'Til Sold Out'
by Richard Belzer
in Amusements, Information Quality, Regulatory Economics
UPDATED. SEE "MORE".
The Panic of 2008 and subsequent recession have put a damper on the wine market, especially at the high end. As a member of too many wine clubs (still the best way to access fine West Coast wine from the East Coast), I have seen more discounting by wineries in the last six months than I observed in the previous six years.
So it should not be surprising to see a bevy of entrepreneurs pop up who are attempting to exploit these depressed conditions. The Los Angeles Times published an intriguing story by reporter Patrick Comiskey about new web-based vendors doing exactly what we'd expect ("Good deals go fast on wine websites," July 8, 2009). Of the vendors Comiskey mentions, Wines 'Til Sold Out seems to have the most unusual business plan: they sell tranches of a single wine, one at a time, first come first served, presumably (but not verifiably) until they are sold out -- then move on to another wine.
After reading the article, I signed up with Wines 'Til Sold Out to investigate.
More...3 Jul 2009
National Organic Program:
Is it 'going to seed'?
by Richard Belzer
in Regulatory Policy
Washington Post staff writers Kimberly Kindy and Lyndsey Layton say the US Department of Agriculture's National Organics Program is falling short, allowing synthetic ingredients or to be used in making organic foods.
In their long Page One story, Kindy and Layton never reveal crucial facts about the National Organic Program: it's a marketing program, not a food safety program.
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...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...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...
