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

April 27, 2018

By: Brian F. Mannix
The EPA has proposed to repeal the greenhouse gas (GHG) emissions guidelines for electric generating units issued on October 23, 2015—better known as the Clean Power Plan (CPP). The Agency has also sought comment separately on what, if anything, ought to replace it. This comment, often drawing on earlier comments, will focus on the Regulatory Impact Analysis (RIA) that supported EPA’s 2015 CPP final rule, and outlines those areas where the agency made major errors in the 2015 RIA, and where it could go further to improve the analysis.

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

April 09, 2018

By: Brian F. Mannix, Sofie E. Miller, & Susan E. Dudley
The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach. As part of its mission, the GW Regulatory Studies Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on the Office of Management and Budget’s 2017 Draft Report to Congress offers suggestions for improving the information value of the Report, as well as the evidence on which regulatory policies depend, and does not represent the views of any particular affected party or special interest.