Public Comments & Testimonies

STB Petition to Consider Benefit-Cost Analysis

January 31, 2020

On July 8, 2019, the STB decided to delay consideration of a petition asking the board to adopt a procedural rule that would require benefit-cost analysis in certain board rulemakings. 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. The STB is prudent to explore methods for improving its economic analysis of regulatory proposals—as several other independent agencies have done in recent years.

GSA's Mass and Fake Comments Meeting

January 30, 2020

Over the last few years, we've been, with a bunch of colleagues at George Washington University, working on a project on mass comment campaigns and agency rulemaking. And I want to spend a few minutes sharing what we've been up to, what we've found. And what we think some of the broader implications of the research are, but for the larger interests we're discussing today.

FDIC's Framework for Analyzing the Effects of Regulatory Actions

January 29, 2020

The FDIC is considering a more structured approach to economic analysis that informs regulatory decisions. The RFI seeks comment on an approach that is based on Circular A-4, the Office of Management and Budget’s peer-reviewed guidance for conducting regulatory impact analysis (RIA) under Executive Order 12,866, as well as economic analysis guidance issued by other financial regulators.

STB's Railroad Revenue Adequacy

January 24, 2020

The Staggers Rail Act of 1980 deregulated most freight rail rates but left the Interstate Commerce Commission (and now the STB) with responsibility for ensuring that rail rates are “just and reasonable” for shippers who lack good transportation alternatives to a single railroad.

STB's Rate Review and Market Dominance -- Reply Comment

January 13, 2020

In two related proceedings, the STB has proposed a streamlined approach to assessing whether a railroad has market dominance and a final offer process for small rate disputes.

STB's Market Dominance and Final Offer Rate Review

November 6, 2019

The Staggers Rail Act of 1980 deregulated most freight rail rates but left the Interstate Commerce Commission (and now the STB) with responsibility for ensuring that rail rates are “just and reasonable” for shippers who lack good transportation alternatives to a single railroad.

DOE's Energy Conservation Standards for Manufactured Housing

August 16, 2019

Summary

FDA's Proposed Rule on Mammography Standards

June 23, 2019

Early detection of breast cancer can save lives. Mammography is one of the screening tools that has contributed to reductions in breast cancer mortality. FDA has a unique role in mammography and should be commended for proposing to update its rules, particularly for those updates that reflect new technologies, such as the provisions related to digital mammography that update old regulatory terms like “x-ray film.”

From Beginning to End: An Examination of Agencies' Early Public Engagement and Retrospective Review

May 7, 2019

My testimony reviews the problems necessitating the practices required by your legislation and addresses and examines each bill’s requirements and impacts. It concludes with some crosscutting comments and observations.

DOE's Energy Conservation Program for Appliance Standards

May 7, 2019

In a notice of proposed rulemaking (NPRM), DOE is proposing to “update and modernize the Department’s current rulemaking methodology titled, ‘Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products’ (‘Process Rule’).”