Public Comments & Testimonies

Scholarly analysis of the potential effects of particular rulemakings from federal agencies, and advice to Congress on how to improve the rulemaking process by GW Regulatory Studies Center scholars.


"Your input and expertise during the drafting of the Early Participation in Regulations Act of 2019 and SMART Act of 2019 was invaluable."

Senator Kyrsten Sinema (D-AZ)
Senator James Lankford (R-OK)

Joint statement


Examining Practical Solutions to Improve the Federal Regulatory Process

Testimony before the United States Senate Subcommittee on Regulatory Affairs and Federal Management Roundtable Discussion hearing on Examining Practical Solutions to Improve the Federal Regulatory Process.

Recommendations for Improving the Regulatory Process

The George Washington University Regulatory Studies Center is pleased to respond to the request by Senate Homeland Security and Government Affairs Committee Chairman Johnson, Ranking Member Carper, Subcommittee Chairman Lankford, and Ranking Member Heitkamp for recommendations for improving the regulatory process.

FAA's Proposed Rule: Operation and Certification of Small Unmanned Aircraft Systems

The FAA suggests that this rule will be the first step in a long, complex path of integrating unmanned aircraft systems (UAS) into the National Airspace System. However, it will be a challenge for the Administration to ensure that this incremental approach occurs at a pace that closely mirrors market and technological changes.

DOL's Proposed Rule: Discrimination on the Basis of Sex

The DOL Office of Federal Contract Compliance Programs (OFCCP) enforces Executive Order 11,246 (Executive Order), a 1965 order that prohibits Federal contractors and subcontractors and federally assisted construction contractors from discriminating on the basis of race, color, religion, sex, sexual orientation, gender identity, or national origin and requires them to take affirmative action to prevent discrimination based on these protected categories.

EPA's National Ambient Air Quality Standards for Ozone

EPA’s proposed determination that existing ozone NAAQS are not requisite to protect public health with an adequate margin of safety is not justified by the evidence it presents.

EPA's CO2 Emission Guidelines for Existing Stationary Sources – Electric Utility Generating Units

EPA's proposed rule sets state-by-state carbon intensity targets for the production of electricity.

DOE's Proposed Efficiency Standards for Commercial Heating and Cooling Equipment

The Department of Energy's proposed rule amends the existing energy efficiency standards for commercial unitary air conditioners (CUAC) and commercial unitary heat pumps (CUHP), which are used for space conditioning of commercial and industrial buildings.

NHTSA’s Advance Notice of Proposed Rulemaking: Federal Motor Vehicle Safety Standards: Vehicle-to-Vehicle (V2V) Communications

In August 2014, the National Highway Traffic Safety Administration (NHTSA) issued an Advanced Notice of Proposed Rulemaking (ANPRM) and an accompanying technical report to initiate the rulemaking process to establish a new Federal Motor Vehicle Safety Standard (FMVSS No. 150) that would require vehicle-to-vehicle (V2V) communication capabilities in new passenger cars and light truck vehicles.

FDA's Sanitary Transportation of Human and Animal Food

The proposed regulation would establish criteria for sanitary transportation practices, such as properly refrigerating food, adequately cleaning vehicles between loads, properly protecting food during transportation, and strengthening record-keeping standards.