Recent Research

Susan Dudley

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

Public Interest Comment on DOE's Proposed Efficiency Standards for Commercial Heating and Cooling EquipmentSofie E. Miller, December 1, 2014

Stakeholder Participation and Regulatory Policymaking in the United States, Steven J. Balla & Susan E. Dudley, November 7, 2014

Public Interest Comment on the Proposed Definition of "Waters of the United States" Under the Clean Water Act, Tracy Mehan, November 7, 2014

Public Interest Comment on the CFPB's Proposed Home Mortgage Disclosure (Regulation C)Lindsay M. Scherber, October 29, 2014

Public Interest Comment on NHTSA's Advance Notice of Proposed Rulemaking: Vehicle-to-Vehicle (V2V) Communications, Gerald W. Brock & Lindsay M. Scherber, October 21, 2014

Australia’s Regulatory 'Bonfire'Jeff Bennett & Susan E. Dudley, Regulation Magazine, Fall 2014

Looking Back to Move AheadSofie E. Miller, Regulation Magazine, Fall 2014

Tight Budgets Constrain Some Regulatory Agencies, But Not All, Susan E. Dudley & Melinda Warren, Regulation Magazine, Fall 2014

What's Wrong with the Back of the Envelope? A Call for Simple (and Timely) Benefit-Cost Analysis, Christopher Carrigan & Stuart Shapiro, October 7, 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.

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

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.


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.


The CPSC's Off-Road Adventure

Side by side
March 23, 2015
by Joseph Cordes and Blake Taylor

This article raises issues with the Consumer Product Safety Commission's proposal to regulate recreational off-highway vehicles, commonly referred to as side by sides. CPSC issues rules to mitigate "unreasonable risks." In order to deem a risk as either reasonable or unreasonable, it is necessary to have information on the risk rate. The CPSC, however, proposed this rule without reliable information on the rates of injury and death associated with use of side by sides. Additionally, it is possible that the proposal rule, if enacted, would have a negative impact on consumer surplus if the safety standards make the products undesirable. Such a loss, however, is absent in the Commission's assessment of expected benefits and costs.


Public Comment: National Ambient Air Quality Standards for Ozone

Ozone image
March 17, 2015
by Louis Anthony (Tony) Cox, Jr.

EPA’s quantitative risk estimate (QRA) provides no legitimate reason to believe that the proposed action is “requisite to protect public health” or that reducing the ozone standard further will cause any public health benefits. Given EPA’s information and the unquantified model uncertainty that remains, there is no sound technical basis for asserting with confidence, based on the models and analyses in EPA’s ozone risk assessment, that an ozone standard of 65 ppb would be any more protective than 70 ppb, or that 80 ppb is less protective than 60 ppb. To the contrary, available data suggest that further reductions in ozone levels will make no difference to public health, just as recent past reductions in ozone have had no detectable causal impact on improving public health.


The Oxford Handbook of Classics in Public Policy and Administration

Oxford Handbook
March 26, 2015
Edited by Steven J. Balla, Martin Lodge, and Edward C. Page

This Handbook brings together a collection of leading international authors to reflect on the influence of central contributions, or classics, that have shaped the development of the field of public policy and administration. Each classic is discussed by a leading international scholars. They offer unique insights into the ways in which individual classics have been received in scholarly debates and disciplines, how classics have shaped evolving research agendas, and how the individual classics continue to shape contemporary scholarly debates. In doing so, this volume offers a novel approach towards considering the various central contributions to the field.


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.


COMMENTARY: Improving Regulatory Accountability: Lessons from the Past, Prospects for the Future

Illustration of America wrapped up in red tape
Illustration: Keith Bendis, U.S. Chamber of Commerce website
February 17, 2015
by Susan E. Dudley, Director

There are now more than 70 federal agencies, employing almost 300,000 people, that write and implement regulations. Every year, they issue tens of thousands of new regulations, which now occupy over 175,000 pages of code. Concerns over the accountability of what some have called the "fourth branch" of government have led all three branches of government to take steps to exercise checks and balances. Like the bipartisan regulatory reform efforts of the 1970s and 1980s, reforms today could spur economic growth and improve the welfare of American families, workers and entrepreneurs.