Recent Research

Susan Dudley


Public Interest Comment on the Department of Transportation's Proposed Rule: Transparency of Airline Ancillary Fees and Other Consumer Protection Issues, Sofie Miller, September 17, 2014

Comment on OMB's Report to Congress on Benefits and Costs of Federal Regulations, Susan Dudley, Brian Mannix, and Sofie Miller

Valuation of PM 2.5 Reductions in OMB's Report to Congress on Benefits and Costs of Federal regulations, Tony Cox, September 2,2014 

Bank Disclosure and incentives, Korok Ray, August 15, 2014

Comment on the DOL's Proposed Minimum Wage for Federal Contractors , Connor Roth and Mark Bigley, July 28, 2014

Retrospective Review Comment on FDA's Proposed Nutrition Fact Label Revisions, Ian Smith, July 28,2014

The Social Cost of Carbon, Susan Dudley and Brian Mannix, July 24, 2014 

Recommendations to DOE on Reducing Regulatory Burden , Sofie E. Miller , July 17, 2014

Retrospective Review Comment on the Department of Education’s Proposed Violence Against Women Act Rule, Julia Morriss, Summer Fellow, July 17, 2014

Retrospective Review Comment on EPA's Proposed Agricultural Worker Protection Standards for Pesticides, Connor Roth, Summer Fellow, July 14, 2014

2015 Regulators' Budget: Economic Forms of Regulation on the Rise, Susan Dudley & Melinda Warren, July 2014

Retrospective Review Comment on FDA's Proposed e-Cigarette , Estelle Raimondo, July 7, 2014

Retrospective Review Comment on the Federal Reserve Board's Proposed Concentration Limits on Large Financial Companies, Julia Morriss, July 2, 2014

Retrospective Review Comment on SEC's Proposed Reporting Requirements for Swap Dealers, Participants, and Broker Dealers ,Mark Bigley, July 1, 2014

Retrospective Review Comment on DOE's Proposed Energy Efficiency Standards for Fluorescent and Incandescent Lamps, Sofie E. Miller, June 30, 2014

Retrospective Review Comment on FDA's Sanitary Transportation of Human and Animal Food, Philip J. Austin, June 16, 2014

Retrospective Review Comment on the Proposed Rule: Minimum Requirements for Appraisal Management Companies under the Dodd-Frank Act, Ian Smith, June 9, 2014

Determining the Proper Scope of Climate Change Benefits, Ted Gayer & Kip Viscusi, June 4, 2014

Retrospective Review Comment on the Department of Education's Proposed Rule: Program Integrity: Gainful Employment Cassidy B. West, May 27, 2014

Retrospective Review Comment on DOE's Proposed Efficiency Standards for Commercial Ice Makers, Sofie E. Miller, May 16, 2014

Retrospective Review Comment on the FMCSA's Proposed Rule: Electronic Logging Devices and Hours of Service Supporting Documents, Susan E. Dudley, May 15, 2014

About the 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.

Public Interest Comment on the Department of Transportation's Proposed Rule: Transparency of Airline Ancillary Fees and Other Consumer Protection Issues

September 17, 2014
by Sofie Miller

The proposed rule is intended to "enhance protections for air travelers and improve the air travel environment" by establishing certain transparency and disclosure requirements for airlines, global distribution services, and ticket agents. The Department for Transportation is proposing to require airlines to disclose and ticket agents to display ancillary fees—such as for checked bags, carry-on bags, and advance seat selection—at all points of sale. While airlines are currently required to display ancillary and optional airline fees, many travelers now rely on meta-search engines (such as Kayak, Google, and Expedia) to compare and purchase airfare, and the Department is concerned that consumers aren’t being provided with code-share disclosure and ancillary fee information.


Commentary: New Study Finds Federal Regulation Costs Over $2 Trillion per Year and Disproportionately Affects Small Businesses

New Study by NAM
September 10, 2014
by Susan E. Dudley

The costs of regulation, both individually and in the aggregate, are notoriously hard to measure. Unlike the direct costs of government programs, which are tracked through the fiscal budget, there is no mechanism for keeping track of the off-budget costs imposed by regulation. Thus, to get a clearer picture of the impact of regulations, it is important to examine those impacts through different lenses using different measurement tools, even though none of those approaches is perfect.


Comment on OMB's Report to Congress on the Benefits and Costs of Federal Regulation

OMB Figure 1-1
September 02, 2014
By Susan E. Dudley, Brian F. Mannix, & Sofie E. Miller

OMB’s Draft 2014 Report to Congress on the Benefits and Costs of Federal Regulations (the Report) provides the Congress and the public with valuable information both on estimates of the effects of major executive branch regulations and also on OMB’s focus and priorities as it reviews agency regulations. This comment addresses several topics covered in the Report: 1) implementation of President Obama’s retrospective review initiative, 2) aggregate benefits and costs, and issues associated with their estimation, 3) effects of regulations issued by independent regulatory agencies, 4) presentation of trends in regulatory benefits and costs, 5) distributional impacts, and 6) employment effects.


Valuation of PM 2.5 Reductions in OMB's Report on the Benefits and Costs of Federal Regulation

September 02, 2014
By Tony Cox, Visiting Scholar

In this comment on OMB's draft report, Visiting Scholar Tony Cox argues that EPA mistakenly treats causality as if it were dichotomous: something that can be determined to be either present or not in interpreting epidemiological evidence. However, this is an oversimplification. In reality, some fraction of an epidemiological association might be due to a causal impact of one variable on another. Another fraction might be explained by confounding; a third part might result from model specification error, a fourth from unmodeled uncertainties in estimated values of explanatory variables, and so forth. Thus, the true challenge facing regulators should not be represented as being to make a determination about whether evidence supports a causal interpretation (a yes-no determination), but rather to determine what fraction (if any) of an association is causal. For PM2.5 and human health effects, this causal fraction has never been determined. Yet, without knowing it, policymakers lack the crucial factual information required to make well-informed policy decisions based on the probable health consequences of alternative choices.


Latest Commentary: A Retrospective Review of Regulatory Review Itself

Council on Wage and Price Stability
August 26, 2014
by Brian Mannix

An interesting new paper from the Mercatus Center, “The Legacy of the Council on Wage and Price Stability”,[1] takes an instructive look back at the origins of centralized review of federal regulations. While the President has always had the authority to supervise executive branch regulatory actions, there were few formal procedures, and no dedicated professional staff within the Executive Office of the President, until the creation of the Council on Wage and Price Stability (CWPS) in 1974.


Bank Disclosure and Incentives

August 15, 2014
By Korok Ray, Visiting Scholar

In this working paper, Korok Ray proposes a microeconomic model of a bank that acts as a financial intermediary engaging in maturity transformation, borrowing short-term debt from a market of investors to fund a long term loan to a firm. The bank installs a manager who exerts costly effort to reduce the credit risk of the loan portfolio. Disclosing this credit risk to the market increases the manager’s incentives for risk management. The market rewards the manager’s early efforts to manage risk with a lower future cost of debt. When paid on bank equity, the manager is induced to better manage risk. Disclosure therefore helps resolve the moral hazard problem inside banks.


OPINION: Paul Ryan Anti-Poverty Plan Targets Regressive Regulation

Sofie E. Miller
August 07, 2014
By Sofie E. Miller in Roll Call

According to Rep. Ryan’s anti-poverty plan, federal regulations impose a heavy burden on low-income American households. Our research at the George Washington University Regulatory Studies Center shows just that: regulations often leave low-income Americans paying a heavier price than their neighbors. These rules don’t address immediate risks to public health or safety, but they do limit consumer choices and increase prices, which disproportionately impacts low-income households. While some Americans can make room in their budgets for more expensive fuel, groceries, and appliances, those who can’t are left to make tough decisions about how to spend limited household resources. Ryan’s anti-poverty plan would require agencies to determine the effects of the rules on low-income Americans, and would require Congress to review federal regulations that would disproportionately affect the nation’s poorest households. Given the disproportionate impact of regulations on low-income Americans, these reforms are a step in the right direction for ensuring that federal regulations do more good than harm.


The Social Cost of Carbon


Engage Volume 15, Issue 1

This article is based on a comment we filed on the public record, which made four points. First, we endorsed the administration’s effort to arrive at a uniform social cost of carbon (SCC), to help ensure at least internal consistency across a portfolio of policies directed at reducing carbon emissions. Second, we applauded the Office of Management and Budget’s (OMB’s) effort to seek public comment on its technical support document (TSD), and urged the administration to follow through with scientific peer review and with other measures to ensure transparency in regulatory decisions. Third, we cautioned that the task of estimating the SCC was undertaken with an apparent bias that needs to be corrected before it can be taken as objective. Finally, we pointed out that the logical next step is not, contrary to the subtitle of the TSD, for regulatory agencies to incorporate the SCC into Regulatory Impact Analyses (RIAs). Rather, the next step is to seek an international consensus on the value of the SCC and to negotiate a coordinated global policy response, which is the only way that the theoretical benefits of government actions to reduce global carbon emissions can be translated into actual results.

Comment on the DOL's Proposed Minimum Wage for Federal Contractors

Dept. of Labor logo
July 28, 2014
By Connor Roth & Mark Bigley

The Department of Labor’s proposal to increase the minimum wage for federal contractors is implicitly based on presumed causal linkages between minimum wages, worker productivity, and more economic and efficient government programs. In its final rule, as required by Executive Order 13563, the Department should identify what measures will be appropriate to evaluate the rule’s success at meeting its stated goals. To do this, the final rule should lay out a plan for retrospective review to validate these assumed linkages, and measure outcomes and intermediate impacts. DOL should also commit to examining possible unintended consequences (such as fewer jobs available for low-skilled workers at the higher wage) and any mediating factors that might influence outcomes.


How to Improve Retrospective Review and Reduce Regulatory Burdens

Dept. of Energy
July 18, 2014
By Sofie Miller, Senior Policy Analyst

Through its Regulatory Burden Request for Information (RFI), DOE is seeking comment from the public on how to effectively review its existing regulations, pursuant to Executive Order 13563. In response to this RFI, we filed a comment offering three recommendations to DOE to further its retrospective review efforts.First, DOE should incorporate plans for retrospective review into its economically significant or major rules. Second, DOE should allow enough time between its energy efficiency standards to allow for an effective review of each rule’s effects before issuing updated rules. Third, DOE should use the Herfindahl-Hirschman Index to measure whether its existing energy efficiency standards have had negative effects on competition in the regulated industries.