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Recent Research

Susan Dudley

2016 Regulators' Budget: Increases Consistent with Growth in Fiscal Budget, Susan E. Dudley & Melinda Warren, May 19, 2015

Uncertainty in the Cost-Effectiveness of Federal Air Quality Regulations, Krutilla et al., May 8, 2015

Recommendations for Improving the Regulatory Process, May 4, 2015

Public Interest Comment on the Federal Aviation Administration's Proposed Rule: Operation and Certification of Small Unmanned Aircraft Systems, Blake Taylor, April 24, 2015

Public Interest Comment on the Department of Labor's Proposed Rule: Discrimination on the Basis of SexLynn White, Esq., April 16, 2015

Public Comment: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z), Blake Taylor, March 23, 2015

Public Comment: National Ambient Air Quality Standards for Ozone, Tony Cox, March 17, 2015

Will the Occupational Safety and Health Administration's Proposed Standards for Occupational Exposure to Repsirable Crystalline Silica Reduce Workplace Risk?Dudley & Morriss in Risk Analysis

The CPSC's Off-Road Adventure, Joseph Cordes & Blake Taylor, March 23, 2015

Achieving Regulatory Policy Objectives: An Overview and Comparison of U.S. and EU Procedures, Susan Dudley & Kai Wegrich, March 2015

Improving Weight of Evidence Approaches to Chemical Evaluations, Lutter et al. in Risk Analysis, February 2015

Improving Regulatory Accountability: Lessons from the Past and Prospects for the Future, Susan Dudley, January 21, 2015

Public Comment: CO2 Emission Guidelines for Existing Stationary Sources – Electric Utility Generating Units, Brian F. Mannix, December 2, 2014

 

The George Washington University Regulatory Studies Center

Susan Dudley with Kathryn Newcomer

The GW Regulatory Studies Center's mission is to improve regulatory policy by raising awareness of regulations’ effects through research, education, and outreach.

The Center is a leading source for applied scholarship in regulatory issues, and a training ground for anyone who wants to understand the effects of regulation and ensure that regulatory policies are designed in the public interest.

Regulatory Action Holding Steady in Spring 2015 Unified Agenda

Chart
May 22, 2015
Sofie E. Miller, Senior Policy Analyst

On the Thursday before the Memorial Day holiday weekend, the Office of Information and Regulatory Affairs released its semiannual Unified Agenda of Regulatory and Deregulatory Actions, which provides the public with a first glimpse at upcoming regulations. The Spring 2015 Agenda lists 1,054 final rules and 1,171 proposed rules on which agencies will take action within the coming year. Of these active regulatory actions, 140 are "economically significant."

Publication

One Discount Rate Fits All? The Regressive Effects of DOE's Energy Efficiency Rule

Cover of Policy Perspectives magazine
May 20, 2015
Sofie E. Miller (in Policy Perspectives Vol. 22)

This paper examines the Department of Energy's (DOE) reliance on low discount rates to estimate the benefits of its energy efficiency standards and uses existing literature on implicit consumer discount rates to calculate a range of benefits for DOE’s furnace fan rule. While DOE calculates large net benefits from its energy efficiency rule, using discount rates that better represent average consumer time preferences shows that this standard results in net costs. Furthermore, given the variation in consumer discount rates by income, this standard is effectively a transfer payment from low- and median-income households to high-income households.

Publication

COMMENTARY: Regulators' Budget Increases Consistent with Growth in Fiscal Budget

Reg Budget figure 1: budgetary costs of regulation over time
May 19, 2015
Report finds that spending on regulatory agencies keeps pace with overall budget

Every year, Susan Dudley and Melinda Warren examine the on-budget costs of regulation by examining the portion of the Budget of the United States devoted to developing and enforcing federal regulations. In this year's report, Dudley and Warren find that the regulators’ budget is growing at approximately the same pace as the overall Budget, 5.3 percent in real (inflation-adjusted) terms in FY 2016 and 4.3 percent in FY 2015. The President’s proposed budget for the regulatory activities tracked here is $66.8 billion in FY 2016. Some of the largest increases reflect Presidential priorities, such as financial market reform and immigration reform.

Publication

2016 Regulators' Budget: Increases Consistent with Growth in Fiscal Budget

Reg Budget report cover
May 19, 2015
By Susan E. Dudley & Melinda Warren

This report tracks the portion of the Budget of the United States devoted to developing and enforcing federal regulations from 1960 to 2016. It presents the President’s requested budget outlays in fiscal year (FY) 2016, as well as estimated outlays for FY 2015 as reported in the Budget of the United States Government for Fiscal Year 2016. This “regulators’ budget” reflects the on-budget costs of regulation. This report finds that the regulators’ budget is growing at approximately the same pace as the overall Budget, 5.3 percent in real terms in FY 2016 and 4.3 percent in FY 2015. The President’s proposed budget for the regulatory activities tracked here is $66.8 billion in FY 2016; estimated outlays in FY 2015 are $62.4 billion. The Budget also requests increases in federal regulatory agency personnel of 1.2 percent in FY 2016 and 0.2 percent in FY 2015. Staffing at regulatory agencies is expected to exceed 280,500 people in 2016.

Publication

Uncertainty in the Cost-Effectiveness of Federal Air Quality Regulations

Smoke stack
May 08, 2015
By Kerry Krutilla, David H. Good and John D. Graham (Published in The Journal of Benefit-Cost Analysis, Spring 2015)

Estimates of lifesavings from reducing airborne concentrations of fine particles, a common pollutant, often account for more than 90% of the benefits of air regulations issued by the U.S. Environmental Protection Agency. A new study by IU researchers at the School of Public and Environmental Affairs adds to a literature on uncertainties about the mortality risks posed by fine particle exposures, finding a wide range of possible regulatory effects from reducing fine particle pollution. The study, “Uncertainty in the Cost Effectiveness of Nine Air Quality Regulations,” was conducted by a research team including Kerry Krutilla, David Good, and John Graham. The study has been published by Cambridge University Press in The Journal of Benefit-Cost Analysis Volume 6, Issue 1 (Spring 2015).

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Regulatory Reform Lessons from the Land Down Under

Warren Mundy
May 08, 2015
A Conversation with Dr. Warren Mundy

On May 7, 2015, the GW Regulatory Studies Center welcomed Australian Productivity Commissioner Warren Mundy to Washington, D.C. for a series of conversations about Australia’s regulatory system and regulatory reform efforts.

Publication

Recommendations for Improving the Regulatory Process

Susan Dudley with Senator Lieberman
May 04, 2015
Response to the Senate Homeland Security and Governmental Affairs Committee's Letter Requesting Input on its Regulatory Improvement Effort

Regulation is one of the primary vehicles by which federal policy is formulated, and it affects every household, employee, and business in the United States. This document summarizes the key regulatory reform insights from some of our research on regulatory impact analysis, judicial review, congressional oversight, retrospective review, public input, and risk assessment. This research will provide the members of the Senate Homeland Security and Government Affairs Committee with relevant context for their ongoing Regulatory Improvement Effort.

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Public Interest Comment on the Federal Aviation Administration's Proposed Rule: Operation and Certification of Small Unmanned Aircraft Systems

Drone
April 24, 2015
by Blake Taylor, Policy Analyst

The FAA suggests that this rule will be the first step in a long, complex path of UAS integration into the National Airspace System. The Administration will be challenged to ensure that this incremental approach occurs at a pace that closely mirrors market and technological changes. Because UAS are nascent technologies, the FAA has very little information on the potential benefits and risks. Retrospective review involving ambitious data collection is essential to structuring the future steps in the integration framework.

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Public Interest Comment on the Department of Labor's Proposed Rule: Discrimination on the Basis of Sex

Pregnant woman
April 16, 2015
By Lynn White, Esq.

In this proposed rule, the Office of Federal Contract Compliance Programs (OFCCP) attempts to clarify the requirements that contractors must fulfill to ensure nondiscrimination on the basis of sex. The OFCCP understated the total costs of the proposed rule, limiting the regulatory analysis to rule familiarization and new costs associated with providing pregnancy accommodations to a limited number of contractor employees. However, actual costs could reach an estimated $130 million or more per year, according to the author's analysis.

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Does Reducing Ozone Really Improve Human Health?

Ozone
April 08, 2015
by Louis Anthony (Tony) Cox, Jr.

In revisiting the National Ambient Air Quality Standards (NAAQS) for ozone, EPA recently concluded that current standards do not fully suffice to protect public health with an adequate margin of safety and that further reductions would probably further reduce mortalities and morbidities in the population. Central to this conclusion is EPA's determination that "O3 exposures are causally related to respiratory effects, and likely causally related to cardiovascular effects, and that long term O3 exposures are likely causally related to respiratory effects." Remarkably, this key conclusion is not supported by any reliable, objective statistical tests for potential causality. It rests solely on the subjective judgments of selected experts, applied to associational data that show that both ozone levels and adverse health effects are higher in some times and places than in others.

Publication

GW Regulatory Policy Capstone Team Featured in GW Today

GW Capstone Group with members of the Virginia Cyber Security Commission

Over the past four months, Trachtenberg School Master of Public Policy candidates Ewan Compton, Andrew Kim, Lindsay Scherber and Nadia Yassin have put their regulatory policy training to good use while conducting a comparative analysis of Virginia’s cyber security laws on behalf of the Virginia Cyber Security Commission. The group’s capstone project and findings are discussed in greater detail in this GW Today article.

CFPB Should Consider a More Dynamic Approach to Prepaid Debit Card Regulation

Disclosure
April 01, 2015
by Blake Taylor, Policy Analyst

Last December, the Consumer Financial Protection Bureau proposed rules intending to improve consumers’ understanding of their choices in the prepaid debit card market and to protect them from unreasonable fees. There is little to no evidence that the proposal will have desirable consequences related to either consumer or seller behavior. What is likely is that the rule will increased compliance burdens for sellers and limit consumer choice.

Publication

Justices debate benefits and costs of EPA mercury power plant rule

Power plant
March 31, 2015
by Susan E. Dudley, Director

The Supreme Court last week heard oral arguments in Michigan v EPA regarding “whether the Environmental Protection Agency unreasonably refused to consider costs in determining whether it is appropriate to regulate hazardous air pollutants emitted by electric utilities.” The regulation being considered is a key part of the Obama administration’s environmental agenda and would require coal-fired power plant operators to install equipment to reduce mercury and other air pollutants. Section 112 of the Clean Air Act directs the EPA to issue regulations that are “appropriate and necessary” to control hazardous air pollutants, including mercury. Thus, one area of debate is whether a standard that imposes very large costs relative to benefits is “appropriate” under the meaning of the statute.

Publication

Public Comment: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z)

Debit card
March 23, 2015
by Blake Taylor, Policy Analyst

This Consumer Financial Protection Bureau (CFPB or “Bureau”) proposed rule would extend various consumer protections to prepaid account products. Protections for traditional bank account and credit products now exist through Regulation E, which governs electronic funds transfers, and Regulation Z, which governs the use of consumer credit. However, prepaid accounts such as debit cards that can be pre-loaded with funds are currently unregulated. CFPB proposes to amend Regulation E and Regulation Z to apply existing and new protections to these relatively new financial products by imposing various information disclosure, limited liability, error resolution, and consumer credit requirements. Before proceeding, CFPB should gather more updated information on the prepaid debit card market about sellers and buyers of prepaid cards, as required by statute. As this proposal stands, it is likely to increase costs and may reduce access with little or no discernible benefits for card users.

Publication

Will the Occupational Safety and Health Administration's Proposed Standards for Occupational Exposure to Respirable Crystalline Silica Reduce Workplace Risk?

Crystalline 200
March 26, 2015
by Susan E. Dudley & Andrew P. Morriss in Risk Analysis

This article finds that OSHA's proposed rule would contribute little in the way of new information, particularly since it is largely based on information that is at least a decade old—a significant deficiency, given the rapidly changing conditions observed over the last 45 years. The article concludes with recommendations for alternative approaches that would be more likely to generate information needed to improve worker health outcomes.

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Achieving Regulatory Policy Objectives: An Overview and Comparison of U.S. and EU Procedures

Susan Dudley with Kai Wegrich
March 10, 2015
By Susan E. Dudley & Kai Wegrich

This paper aims to provide a descriptive analysis of procedural differences in regulatory development between the United States and the European Union to serve as a factual basis for understanding the regulatory challenges and opportunities for transatlantic trade. It summarizes regulatory procedures in each jurisdiction, dividing the process for establishing regulations into four stages: 1) agenda setting, 2) regulatory development, 3) final determination and opportunities for challenge, and 4) implementation and enforcement. After presenting the procedures in the U.S. and EU, the paper compares how the shared goals for achieving a regulatory system that is evidence based, transparent, and accountable are achieved in the two jurisdictions.

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