Public Comments

The GW Regulatory Studies Center scholars independently pursue high quality research to illuminate regulatory theory, policy, and practice; the Center does not take institutional positions on issues. To maintain its independence and the quality and integrity of its products, the GW Regulatory Studies Center does not accept funding that stipulates predetermined results or that limits dissemination of its scholarly activity or research. While the Center files public comments on specific regulations, it does so from the perspective of the public interest, and will not accept direct funding for individual comments.

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Public Comment on OMB's 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations

December 15, 2015

The Office of Management and Budget’s 2015 Draft Report to Congress provides information on costs and benefits for certain final rules issued between FY 2004 and FY 2014. The Report provides the public valuable information both on estimates of the effects of major executive branch regulations, and also on OMB’s focus and priorities. This comment offers recommendations for improving regulatory impact assessments, writing rules to encourage retrospective review of regulations, and the use of “private benefits” to justify energy efficiency standards.