All Publications

April 28, 2020

Practitioners who want to administer methadone, a schedule II controlled substance, to treat opioid use disorder must first obtain a registration from DEA to operate as a Narcotic Treatment Program (NTP). The Controlled Substances Act (CSA) requires that each person registered with the DEA to dispense controlled substances must obtain a separate registration “at each principal place of business or professional practice.” This requirement generally extends to NTPs. However, the statute also gives DEA the authority to waive this requirement if “consistent with the public health and safety."

Using Public Comments to Identify Regulations for Retrospective Review

April 22, 2020

The difficulty of identifying which regulations to evaluate from the existing stock persists as a barrier to agencies in their efforts to implement retrospective review.

4/30: GSA’s Regulatory Data Public Meeting (& job openings)

April 22, 2020

EPA Proposes to Accelerate Its Permit Appeal Process

April 14, 2020

The U.S. Environmental Protection Agency recently proposed a rule to streamline the process for appealing a permit to the agency’s Environmental Appeals Board.

Using Comments as Data for Research

April 13, 2020

DOT's Proposed Rule for Air Travel with Service Animals

April 7, 2020

The Department of Transportation (DOT) is proposing amendments to its Air Carrier Access Act regulation on the transportation of service animals by air. Multiple parties from a variety of perspectives have called for greater regulatory clarity on what qualifies as a service animal, how airlines should classify emotional support animals (ESAs) for air travel, whether uncommon species should be allowed aboard planes, and how to mitigate health and safety risks caused by animal behavior.

FDA & USDA Food Identity Standards

April 2, 2020

Both FDA and USDA promulgate food identity standards that require foods sold under particular names to have certain characteristics or ingredients that consumers might expect. In 2005, the agencies jointly proposed a rule to establish general principles for evaluating food identity standards.

GAO’s Role in the Regulatory State

March 24, 2020

Reply Comment on Benefit-Cost Analysis at the STB

March 18, 2020

On November 4, 2019, the STB solicited further information from the public about specific methods that could be used for benefit-cost analysis of rules related to economic regulation of freight railroads.

Are Future Lives Worth More Than Our Own?

March 14, 2020

The Environmental Protection Agency has asked its Environmental Economics Advisory Committee (EEAC) for advice on how the Agency should adjust the value of statistical lives (VSL) in the future. Incomes in the future are expected to grow, and people with higher incomes tend to place a higher value on measures to reduce their own mortality risks. Does this mean that a benefit-cost analysis should place greater weight on lives saved in the future than it does on those saved today? In comments filed with the Committee and summarized here, Mannix argues that this is more than just a question of analytical technique.