EPA’s Ozone Rule and the Scientization of Policy
EPA standards on Clean Air Act reflect hidden policy choices
All Publications
In response to a directive from President Obama, and using their respective statutory authorities, the Environmental Protection Agency (EPA) and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) have jointly proposed a set of standards to regulate greenhouse gas emissions and (almost equivalently) fuel efficiency for medium and heavy-duty engines and vehicles.
A Review of Regulatory Reform Proposals
Testimony before the United States Senate Homeland Security & Government Affairs Committee.
Agencies could work more consistently to identify which regulations are likely to have a significant effect on international trade and investment.
The Role of Transparency in Regulatory Governance
This article examines the transparency of procedures in the US and the EU related to impact analysis and public comment. It examines the importance of transparency for ensuring the effectiveness of these two regulatory practices, summarizes regulatory procedures in the US and the EU, compares the different approaches, and highlights the relative merits of each.
Considering the Cumulative Effects of Regulation
Ex-ante regulation-by-regulation analysis may not account for the cumulative effect of regulations on society or specific sectors of the economy.
NRC's Financial Qualifications for Reactor Licensing
In June 2015, the Nuclear Regulatory Commission sought public comment on a draft regulatory basis for a proposed rulemaking to amend the financial qualifications standard for new reactor licensing from the current “reasonable assurance” to the proposed “appears to be financially qualified.” I appreciate the opportunity to comment and encourage NRC to proceed with the proposed rulemaking.