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Susan Dudley

 

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

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.

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.

Publication

Disclosure as a Form of Market-based Regulation

bank
August 18, 2014
By Korok Ray

Since the recent global financial crisis, there has been a tectonic shift in the policy world towards more onerous regulation of the banking sector, primarily, though not exclusively, through the Dodd-Frank Act. Bank regulators not only have more power given to them through Congress, but also from the increase in power of the Federal Reserve and the other major banking regulators in the U.S (OCC, FDIC, etc.). At the same time, there has been widespread acknowledgement that incentives were at the core of the problem leading up to the financial crisis, but little actual research on what those underlying incentive problems were and how they may be resolved.

Publication

Bank Disclosure and Incentives

bank
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.

Publication

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.

Publication

The Social Cost of Carbon

trees

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.

Publication

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.

Publication

Thank You for Not Smoking (e-Cigarettes)

No smoking sign
July 08, 2014
By Estelle Raimondo, Ph.D Candidate in Public Policy and Evaluation Research

The Food and Drug Administration's proposed a rule would deem e-cigarettes (and possibly cigars) to be subject to tobacco product requirements such as ingredient listing, pre-market clearance, free sampling prohibition, minimum age requirement, and limit on sales by vending machines, as well as required health and addiction warning statements. The rule is intended to improve health outcomes by reducing the number of youths and young adults who are exposed to e-cigarettes and cigars. However, there are limited data on the actual impact of e-cigarettes and cigars on health outcomes and addiction patterns. Naturally, there are many unknowns in the proposal, in particular, a lack of evidence specifically about differentiated public health impacts of various tobacco products and of baseline usage patterns and risks. Given the uncertainty and inherent complexity of a regulation such as this one, it is paramount to ensure that the rule is written in a way that allows ex post feedback on whether intended goals have been reached.

Publication