Policy Integrity submits comments to OIRA’s 2010 report to Congress
Each year, the Office of Information and Regulatory Affairs (OIRA) reports to Congress on the costs and benefit of federal regulations.
As we did last year, Policy Integrity again offered comments on OIRA’s draft report, including a suggestion to expand a discussion of the steps that agencies and OIRA have taken in the past year to implement the recommendations in the last report.
Our memo also suggest that OIRA conduct aggregate distributional analysis of regulation in order to determine who bears the burdens and who enjoys the benefits of regulation.
The office should also facilitate retrospective analysis that would compare predicted costs and benefits with reality to see where commonly used assumptions are correct and where they might be wrong. One potential example where retrospective analysis could help is by reducing the overestimation of the time and effort it takes busineses to adapt to new rules.
Policy Integrity also suggested that OIRA review the petitions for rulemakings submitted to the agencies. Doing so would highlight important areas of over or under regulation and allow OIRA to opportunity to suggest potential new rules to agencies. This formal mechanism can help overcome agency inertia that can hamper proactive identification of necessary protections.
And finally, it would make sense for OIRA to identify the inconsistencies between how different agencies treat core regulatory questions so that assumptions used are standardized across agencies.
We look forward to seeing OIRA’s responses to our suggestions when their final report is released early next year.