Public Comments & Testimonies

Scholarly analysis of the potential effects of particular rulemakings from federal agencies, and advice to Congress on how to improve the rulemaking process by GW Regulatory Studies Center scholars.


"Your input and expertise during the drafting of the Early Participation in Regulations Act of 2019 and SMART Act of 2019 was invaluable."

Senator Kyrsten Sinema (D-AZ)
Senator James Lankford (R-OK)

Joint statement


Wasted Energy: DOE’s Inaction on Efficiency Standards and Its Impact on Consumers and the Climate

Testimony in front of the House Energy and Commerce Committee.

NTIA's Approach to Consumer Privacy

NTIA is requesting public comments on its proposed approach to guide federal policymaking related to consumer privacy.

EPA's Proposed “Affordable Clean Energy” (ACE) Rule

EPA’s preliminary Regulatory Impact Analysis (PRIA) calculates that, compared to the status quo ante (i.e., no CPP in effect), the ACE rule will reduce CO2 emissions in 2025 by between 13 and 30 million short tons, resulting in $1.6 billion in monetized domestic climate benefits.

SAFE Vehicles Rule

The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach.

IRS's Proposed Rule on SALT Credits

Many states offer full or partial state tax credits for charitable contributions to or investments in specific types of activities.

ED's Student Assistance & Loan Programs

The Department published a final rule on November 1, 2016 which made substantive changes to its treatment of borrower defenses and other loan discharges (i.e., loan forgiveness for borrowers) related to its Federal Direct Loan Program.

EPA's Repeal of Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

The EPA has proposed to repeal the greenhouse gas (GHG) emissions guidelines for electric generating units issued on October 23, 2015

Council on Environmental Quality - Implementing NEPA

For the first time in 30 years, the Council on Environmental Quality (CEQ) is considering an update to its regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA) of 1969.

Increasing Transparency in Considering Costs and Benefits in the Rulemaking Process -- Update

Attached is a comment that I filed in response to a recent EPA ANPRM to increase transparency in considering costs and benefits in the rulemaking process. I am filing this same comment in the CEQ docket as well, because of the parallels between CEQ’s efforts to bring consistency and transparency to the NEPA process and EPA’s efforts to pursue the same goals with respect to rulemaking.

EPA's Benefit-Cost Analysis in the Rulemaking Process

The EPA is “soliciting comment on whether and how EPA should promulgate regulations that provide a consistent and transparent interpretation relating to the consideration of weighing costs