White House

Regulating Within a Budget

April 23, 2018

By Susan E. Dudley
The Trump Administration’s regulatory budget constraint may help improve agency benefit-cost analyses. (Originally published in The Regulatory Review, a publication of the Penn Program on Regulation).

Spam

Where's the Spam? Mass Comment Campaigns in Agency Rulemaking

April 02, 2018

By: Steven J. Balla, Alexander R. Beck, William C. Cubbison, & Aryamala Prasad
This article examines the occurrence and nature of mass comment campaigns in rulemaking at the Environmental Protection Agency (EPA) between 2012 and 2016. The analysis demonstrates that campaigns of more duplicate or near-duplicate comments occur across issue areas under EPA jurisdictions, and that broad societal constituencies—such as environmentalists—are more active in sponsoring campaigns than specific interests negatively affected by stringent regulations. These findings in some respects confirm and in other respects challenge existing understandings of mass comment campaign participation in administrative rulemaking.