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Department of Commerce – Comments on Manufacturing and Regulation

We recently submitted comments to the Department of Commerce in response to its request for information on the impact of federal regulations on domestic manufacturing. The DOC requested comments on ideas for retrospective review of permitting and regulatory requirements, with a focus on repealing existing “burdensome” requirements. The agency also sought information about the potential adverse impacts of regulations on manufacturing.

We recommended that the retrospective review prioritize reanalysis of regulations for which actual costs and benefits diverge significantly from predicted costs and benefits, because of changing economic circumstances, new technological innovations, emerging scientific understandings, or initial miscalculations. We believe that prioritizing retrospective review based purely on the volume of opposition from regulated entities—without consideration of regulatory benefits—is an irrational and inefficient approach. We also noted that, in our view, regulations have little effect on aggregate employment or unemployment rates. We attached our recent issue brief, Do Environmental Regulations Create or Kill Jobs?, to help make the case.