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.

Table saw

Public Comment on the CPSC’s Proposed Rule: Safety Standard Addressing Blade-Contact Injuries on Table Saws

July 27, 2017

By Sofie E. Miller and Jacob Yarborough
The CPSC’s proposed rule mandates that all table saws sold in the U.S. be equipped with Active Injury Mitigation (AIM) technology. Miller and Yarborough argue that this rule would lead to a monopoly of the table saw market. This monopoly would reduce consumer choice, dramatically raise costs, and stifle innovation. In addition, they question the underlying assumptions and models that the CPSC uses to conduct their benefit-cost analysis and argue that the benefits may be overstated and the costs understated.

FCC seal

Public Comment on The Federal Communications Commission’s Proposed Rule: Restoring Internet Freedom

July 11, 2017

By Gerald Brock, Ph.D, Co-Director
As an independent regulatory agency, the Federal Communications Commission (FCC) is not required to perform a Regulatory Impact Analysis (RIA) of major regulations. In this public interest comment on the FCC’s “net neutrality” rule, Brock argues that it is desirable to conduct RIA voluntarily because they have become the standard method of ensuring careful analysis of proposed regulations in the U.S. and other major countries.

rick perry

Public Comment on DOE’s Request for Information on Reducing Regulation and Controlling Regulatory Costs

July 07, 2017

By Sofie E. Miller
This comment provides the Department of Energy with recommendations on how to reduce regulatory burdens pursuant to Executive Orders 13771 and 13777. Miller recommends that DOE establish consistent internal standards for determining whether a rule is "economically justified," including using a threshold to limit the proportion of consumers who bear net costs. DOE should also review each rule before increasing the stringency of its standards, and consider surveys or other measures of actual consumer behavior to ensure that its assumptions about household appliance energy use are accurate.

Baby goats

How to Regulate Genome-Edited Animals? A Comment on FDA’s Proposed Guidance

June 19, 2017

By Randall Lutter, Ph.D, Visiting Scholar, and Lena Lewis
The FDA is considering an approach to oversight of genome-edited animals that closely follows its current policy regarding genetically engineered animals. Unfortunately, the proposed approach is unwise because the existing policy regarding genetically engineered animals, which it mimics, has itself simply failed. In this public comment, Lutter and Lewis argue that FDA’s draft guidance for genome edited animals lacks a cogent scientific basis, is inconsistent with FDA’s policies regarding genome edited plants, and is unlikely to advance FDA’s mission to protect and promote public health.

air conditioners

Public Comment on DOE's Energy Conservation Standards for Residential Central Air Conditioners and Heat Pumps

April 25, 2017

By Sofie E. Miller
The Department of Energy’s direct final rule amends the energy efficiency standards for residential central air conditioners and split-system heat pumps. However, DOE’s own analysis suggests that up to 45% of households in some regions will bear net costs as a result of these standards, and that consumers would experience greater savings under less stringent energy efficiency standards. Due to the lack of consumer input in the negotiated rulemaking process—and the significant burdens that consumers are likely to bear from this standard—DOE should not pursue this standard via direct final rule.

Eisenhower Building

Public Comment on OMB's Interim Guidance Implementing Section 2 of the Executive Order Titled "Reducing Regulation and Controlling Regulatory Costs"

February 13, 2017

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.