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


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

Agricultural Research and 2018 Farm Bill Implementation

On June 13, 2019, the U.S. Department of Agriculture (USDA) released what it describes as a “Cost-Benefit Analysis” of the proposed relocation of NIFA and ERS from Washington DC to Kansas City.

Increasing Consistency and Transparency in EPA's Benefit Cost Analysis

In this ANPRM, EPA seeks comment on the appropriate role for regulatory analysis in decisions authorized by the different statutes EPA administers. It explicitly does not seek comment on “how best to conduct the underlying analysis of regulatory actions."

DHS's Proposed Rule: Removal of International Entrepreneur Parole Program

The Department of Homeland Security’s proposed rule would eliminate its international entrepreneur (IE) program.

FDA's Proposal to Regulate Nicotine Levels

The U.S. Food & Drug Administration recently published an “Advance Notice of Proposed Rulemaking, Tobacco Product Standard for Nicotine Level of Combusted Cigarettes1" to invite comments and submissions of information for it to consider as it plans to develop a maximum nicotine level for cigarettes. The agency hopes to establish a standard for nicotine levels in cigarettes so that they do not initiate or perpetuate addiction to cigarettes for some portion of potential smokers.

FSIS's Egg Products Inspection Regulations

The Food Safety Inspection Service (FSIS) is proposing to require official plants that process egg products to develop and implement Hazard Analysis and Critical Control Point (HACCP) Systems and Sanitation Standard Operating Procedures (Sanitation SOPs).

FDA’s Advanced Notice of Proposed Rulemaking: Tobacco Product Standard for Nicotine Level of Combusted Cigarettes

FDA’s plan to restrict nicotine to very low levels in combusted cigarettes in order to reduce smokers’ addiction to cigarettes is a novel and creative approach

EPA’s Proposed Rule Strengthening Transparency in Regulatory Science

In this proposal, EPA aims to strengthen the transparency of the science it considers “pivotal” to its significant regulatory actions.

OMB's 2017 Draft Report to Congress on the Benefits and Costs of Federal Regulations

Pursuant to the Regulatory Right-to-Know Act, the Office of Management and Budget (OMB) submits to Congress each year an accounting statement and associated report

DOE's "Process Rule" for Energy Efficiency Standards

The Department of Energy (DOE) is seeking comment on potential modifications to its “Process Rule,” which outlines the Department’s approach to establishing new