Daniel is a policy analyst at the GW Regulatory Studies Center. His professional experience includes work as a private sector energy analyst, where he studied the outcomes and regulatory environment of state-owned oil companies. Daniel’s research interests include privacy, effects of regulation on international trade and investment, the international energy market, and national security. Daniel is also a PhD. student at the Trachtenberg School of Public Policy & Public Administration.
Publications
Public Interest Comments:
NTIA's Approach to Consumer Privacy, November 12, 2018
DHS's Proposed Rule: Removal of International Entrepreneur Parole Program, June 29, 2018
OMB's Interim Guidance Implementing Section 2 of the Executive Order Titled "Reducing Regulation and Controlling Regulatory Costs," February 13, 2017
NHTSA’s Federal Automated Vehicles Policy: Accelerating the Next Revolution In Roadway Safety, November 16, 2016
Commission on Evidence-Based Policymaking, November 8, 2016
DHS’s Proposed International Entrepreneur Rule, October 18, 2016
Dept. of Education's Proposed Rule on Student Assistance General Provisions, Federal Student Loans Programs and Teacher Education Assistance for College and Higher Education Grant Program, August 2, 2016
FDA’s Public Availability of: Draft Environmental Assessment and Preliminary Finding of No Significant Impact Concerning Investigational Use of Oxitec OX513A Mosquitoes, May 13, 2016
National Economic Council on The President's Executive Order 13725: Steps to Increase Competition and Better Inform Consumers and Workers to Support Continued Growth of the American Economy, May 12, 2016
Articles & Working Papers:
Privacy Research: The Need for Evidence in the Design of U.S. Privacy Policy, July 3, 2019
The Relationship Between Regulatory Form & Productivity: An Empirical Application to Agriculture, June 12, 2019
Planning for Everything (Besides Death and Taxes), April 3, 2019
Measuring Costs and Benefits of Privacy Controls: Conceptual Issues and Empirical Estimates, January 30, 2019
A Taxonomy of Regulatory Forms, May 30, 2018
A Proposed Framework for Evidence-Based Regulation, February 22, 2018
Measuring Costs and Benefits of Privacy Controls: Conceptual Issues and Empirical Estimates, November 6, 2017
Regulatory Impact on Corn Farming: Transatlantic Agriculture & Regulation Working Paper Series: No. 5, October 24, 2017
Transatlantic Approaches to Agriculture Policy: Transatlantic Agriculture & Regulation Working Paper Series: No. 3, October 4, 2017
Agricultural Statistics: Transatlantic Agriculture & Regulation Working Paper Series: No. 1, September 20, 2017
Briefly Noted: Obama’s Midnight, April 14, 2016
Identifying Regulations Affecting International Trade and Investment: Better Classification Could Improve Regulatory Cooperation, November 10, 2015
Commentaries:
2019 Spring Unified Agenda, May 22, 2019
Policy Analysis for Uncertain Futures, March 13, 2019
The Government Shutdown's Effect on Regulatory Output, February 6, 2019
2018 Fall Unified Agenda, October 17, 2018
Fiscal Year 2018 Report on Regulatory Reform under Trump, October 17, 2018
Spring Unified Agenda Sustains Deregulatory Focus, May 10, 2018
President Trump's State of the Union claim on Regulation: The 2017 Data are In, February 1, 2018
Federal Agency Rulemaking across Administrations, August 28, 2017
The Window on Low-Hanging Fruit in Regulatory Reform is Closing, May 10, 2017
More Historic “Firsts” for Regulatory Disapprovals under the Congressional Review Act, April 4, 2017
President Trump Signs First Regulatory Disapproval in 16 Years, February 15, 2017
A Useful Measure of Regulatory Output, January 11, 2017
The Midnight Uptick: Hasty Turnaround for Costly Student Loan Rule, November 2, 2016
The Renewable Fuel Standard’s Contribution to National Security is Misconstrued by its Advocates, September 29, 2016
Reaching Across Borders: U.S. – EU Regulatory Cooperation in Practice, September 20, 2016
Reforms to Student Loans Create More Problems Than They Fix, August 3, 2016
Protectionist Rhetoric Continues as U.S. and EU Wrap-Up 13th Round of Trade Talks, May 4, 2016
The Role of FDA Regulations in the Fight Against the Zika Virus, February 17, 2016
President Obama’s Regulatory Output: Looking Back at 2015 and Ahead to 2016, January 12, 2016
Insights on South Korea's Public-Private Partnership for Regulatory Reform, December 21, 2015
Midnight Rules: A Comparison of Regulatory Output Across Administrations, December 1, 2015
Early Notice from U.S. Agencies Could Help Avoid Creating Barriers to Trade, November 11, 2015
Consistent Inconsistencies: Misclassification of Rules Could Hamper International Regulatory Cooperation, August 26, 2015
In the News:
Bloomberg, Deregulation Window Closing 17 Months Before Trump Term Ends, cites Daniel R. Pérez, August 14, 2019
Bloomberg, Trump Boasts of 'Record' Savings From Deregulation, cites Daniel R. Pérez, October 17, 2018
The Hill, Boosting integrity of federal policymaking is an easy win for Congress, November 28, 2017, by Susan E. Dudley and Daniel R. Pérez
E&E News: SEC rule repeal sets stage for unprecedented legal fight, February 10, 2017, quoting Daniel Pérez
RegBlog: Measuring the Obama Administration's Historic Midnight Surge, February 6, 2017, by Sofie Miller & Daniel Pérez
Washington Post: With days left in office, President Obama ushers in dozens of policies. But will they stay seated?, January 15, 2017, quoting Daniel R. Pérez
Bloomberg BNA: Total Rules Drop, but Costly Ones Climb Under Obama, January 13, 2017, citing Daniel R. Pérez
Recent Articles
2019 Spring Unified Agenda
5/22/19 - The Spring 2019 Unified Agenda includes a total of 3,791 actions, 295 of which are classified as regulatory, 721 as deregulatory, with the remainder exempt or classified as “other.” Of the total number of actions, 177 are economically significant. The agencies with the most deregulatory actions planned are the Department of Transportation (DOT) with 129 actions and the Department of Health and Human Services (HHS) with 65; these same two agencies have had the most deregulatory actions planned since the Fall 2017 Agenda.
Measuring Costs and Benefits of Privacy Controls: Conceptual Issues and Empirical Estimates
By Joseph J. Cordes, Co-Director & Daniel R. Pérez, Policy Analyst
As personal information becomes increasingly available to internet providers, the government, and employers, a lively debate has emerged about the role of public policy in ensuring a proper balance between parties who benefit from greater access to information and the protection of individual rights to privacy. Additionally, emerging technologies such as highly automated vehicles and unmanned aircraft systems bring privacy concerns to the forefront—particularly regarding the proper role of federal regulatory agencies. Agency rulemaking requires a thorough analysis of regulatory benefits and costs. Our paper hopes to contribute to the development and greater use of empirical measures of consumer privacy.
Regulatory Impact on Corn Farming: Transatlantic Agriculture & Regulation Working Paper Series: No. 5
By Daniel R. Pérez, Aryamala Prasad, & Zhoudan Xie
The final chapter of the five part series with the USDA and the GW Regulatory Studies Center examines the impact of environmental and food safety regulations on corn production in the U.S. and EU. Using France and Spain as case studies to illustrate the differences that result from EU member states’ translation and implementation of agricultural regulations at the country level, the chapter identifies and discusses regulations affecting corn production and estimates the economic impact of each regulation at the farm level. The use of a typical farm approach demonstrates relative differences in outcomes for farms among different jurisdictions.
Examining How Small Businesses Confront and Shape Regulations
By Sofie E. Miller & Daniel R. Pérez
On March 29th, the U.S. Senate Committee on Small Business & Entrepreneurship met to consider legislative reforms that would affect how small businesses confront and shape regulations. This prepared statement for the record focuses on S. 584: Small Business Regulatory Flexibility Improvements Act. The analysis suggests that the Committee should: be careful to avoid the problem of double-counting indirect costs, use an evidence-based regulation framework to strengthen retrospective review, and safeguard against unintentionally reducing the efficacy of the existing Small Business Advocacy Review process.
Public Comment on OMB's Interim Guidance Implementing Section 2 of the Executive Order Titled "Reducing Regulation and Controlling Regulatory Costs"
By Susan E. Dudley, Brian F. Mannix, Sofie E. Miller, & Daniel R. Pérez
In this comment on the Office of Information and Regulatory Affairs’ (OIRA) interim guidance on Executive Order 13771, GW Regulatory Studies Center scholars acknowledge that the Order represents a significant departure from past practice, however, they emphasize that the additional budgeting constraints it imposes need not supplant longstanding requirements to examine regulatory benefits as well as costs and to achieve regulatory objectives as cost-effectively as possible. The comment reinforces OIRA’s draft questions and answers, and offers some suggestions for clarification and improvement.
Public Comment on NHTSA’s Federal Automated Vehicles Policy: Accelerating the Next Revolution In Roadway Safety
By Sofie E. Miller, Howard Beales and Daniel R. Pérez
This comment on the National Highway Traffic Safety Administration’s (NHTSA) recent Federal Automated Vehicles Policy considers the impact of regulating driverless car technology on innovation and social welfare. NHTSA is correct to be cautious of the effects that a federal policy could have on innovation, particularly because the safety gains from highly automated vehicles (HAV) could be significant. As a result, the agency should avoid any type of premarket approval authority for HAV technology, which could potentially delay the adoption of life-saving innovations and result in thousands of traffic fatalities.
Public Comment to the Commission on Evidence-Based Policymaking
By Marcus Peacock, Sofie E. Miller and Daniel R. Pérez
Scholars at the GW Regulatory Studies Center show how the U.S. could make regulations more evidence-based in a comment to the Commission on Evidence-Based Policymaking. Evidence-based regulations plan for, collect, and use evidence to predict, evaluate and improve societal outcomes throughout the rule’s life. This comment lays out a process for producing such rules and provides over a dozen specific recommendations on how the U.S. could better adopt and implement such a system.
Public Comment on The Department of Homeland Security’s Proposed International Entrepreneur Rule
By Daniel R. Pérez
The Department of Homeland Security’s proposed rule would expand the use of its discretionary authority to parole individuals into the United States for reasons of “significant public benefit” to include foreign entrepreneurs looking to start a business in the U.S. DHS recognizes that “the full potential of foreign entrepreneurs to benefit the U.S. economy is presently limited since many…do not qualify under existing nonimmigrant and immigrant classifications.” The rule proposes several criteria for approving applicants on a case-by-case basis. This comment proposes several changes that DHS could make to its proposed rule to maximize its potential benefits.
Public Comment on The Department of Education’s Proposed Rule on Student Assistance General Provisions, Federal Student Loans Programs and Teacher Education Assistance for College and Higher Education Grant Program
By Daniel R. Pérez
The total outstanding balance of student loans is currently estimated to be $1.35 trillion, and default rates among borrowers have reached their highest levels in 20 years. The rule proposed by The Department of Education (ED) would make several amendments to regulations governing its Federal Direct Loan Program, including: 1) an expansion of the conditions wherein ED forgives borrowers’ loan balances, 2) additional provisions that broaden its ability to recover losses from institutions, and 3) expanded financial requirements for postsecondary schools. ED estimates this rule could have annual federal budget impacts of up to$4.23 billion.
The Final Countdown: Projecting Midnight Regulations
By Sofie E. Miller and Daniel R. Pérez
The final months of presidential administrations are accompanied by a significant increase in regulatory output as the executive branch relies increasingly on unilateral activity in a rush to implement its remaining policy priorities. This has come to be known as the “midnight period.” This report contains two robust, quantitative models that contribute to the scholarship in this area by: predicting the number of economically significant rules likely to be issued during the Obama administration’s final months, and finding that independent regulatory agencies do not increase their regulatory output during presidential transitions.
Public Comment on FDA’s Public Availability of: Draft Environmental Assessment and Preliminary Finding of No Significant Impact Concerning Investigational Use of Oxitec OX513A Mosquitoes
By Daniel R. Pérez
Genetically-modified mosquitoes hold great promise for addressing mosquito-borne diseases that threaten South Florida. Yet, the Florida Keys Mosquito Control District has been waiting since 2011 for approval from FDA to allow the biotechnology company Oxitec to conduct field trials for this promising technology. This public interest comment points out that the trial poses no appreciable risk to human or animal health or the environment. The unusually lengthy timeframe for approval has unnecessarily limited our ability to combat the spread of life-threatening diseases, like Zika and Dengue.
Public Comment to the National Economic Council on The President's Executive Order 13725: Steps to Increase Competition and Better Inform Consumers and Workers to Support Continued Growth of the American Economy
By Sofie E. Miller, Daniel R. Pérez, Susan E. Dudley & Brian Mannix
This public comment suggests several areas of regulatory policy where federal regulations have hindered, rather than helped, competition, and recommends that agencies take this opportunity to reduce these regulatory barriers to competition.
US-EU Regulatory Cooperation: Lessons and Opportunities
By D. Pérez, S. Dudley, N. Eisner, R. Lutter, D. Zorn and N. Nord
The George Washington University Regulatory Studies Center prepared this report as part of a grant from the European Union to analyze regulatory cooperation between the EU and U.S. The report includes three case studies examining how cooperation has worked in practice between U.S. regulatory agencies and their EU counterparts and an analysis of U.S. regulations likely to have significant effects on international trade and investment. These analyses identify opportunities to reduce incompatible approaches while indicating areas where differences could persist due to issues of national sovereignty and structural differences between countries.
Briefly Noted: Obama’s Midnight
By Daniel R. Pérez
President Obama’s regulatory output to date has already surpassed both of his predecessors, and it is understandable that observers are carefully considering the possible effects of a surge in rules published within this administration’s midnight period. A significant increase in regulatory output is likely to reduce the amount of time available for agencies to seriously consider public comment, affect the quality of oversight that OIRA is able to provide, and also add considerable political constraints on the incoming administration.
Identifying Regulations Affecting International Trade and Investment: Better Classification Could Improve Regulatory Cooperation
By Daniel R. Pérez
Early notice of upcoming regulations that are likely to affect international trade and investment helps U.S. citizens and companies as well as our trading partners. The U.S. has tasked its regulatory agencies with flagging such rules in the semiannual Unified Agenda before they are issued. We compared the number of rules that agencies flagged as likely to have an international impact from 2008 through 2014 with the number of rules we identified, based on our criteria, that were likely to have such an impact. Agencies are currently identifying less than 30% of these rules.
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