Commentary Archive

Susan E. Dudley

Improving Evaluation of Chemical Regulations

August 31, 2016

8/31/16 - Ex-ante regulatory impact assessment has a long tradition in many countries but it necessarily depends on unverifiable assumptions and models of how the world would look absent the regulation, and how responses to regulatory requirements will alter those conditions. In essence, ex-ante analyses are hypotheses of the effects of regulatory actions. More consistent and robust evaluation of regulatory outcomes would allow agencies to test those hypotheses. This would be valuable not only for understanding the effect of past actions, but for improving future decisions.

Sofie E. Miller

Mobile Home Regulations Threaten Access to Affordable Housing

August 22, 2016

8/22/16 - Manufactured homes—formerly known as mobile homes—are an affordable source of housing for many elderly and low-income households throughout the U.S. Recently, DOE proposed new energy efficiency standards for manufactured homes that would increase prices in exchange for reduced long-term operating costs. However, this tradeoff may not make sense for many manufactured home owners who live in climates where the cost savings don’t add up. DOE’s proposal doesn’t pass the benefit-cost test, and increased efficiency will price many consumers—particularly low-income consumers—out of the market for homes entirely.

Marcus Peacock

The Big Squeeze on Regulatory Agencies

August 09, 2016

8/9/16 - The latest tally of the amount of money it will take to run federal regulatory programs this fiscal year is $63 billion, a 0.7 percent increase over last year. With the government’s debt held by the public now 75 percent of GDP any increase in spending may seem generous but, for regulatory program managers, it is a reminder that they are living under increasingly tighter budget constraints than in the past. In this commentary, Peacock examines this significant challenge for regulatory agencies and for the next president.

Daniel R. Pérez

Reforms to Student Loans Create More Problems Than They Fix

August 03, 2016

8/3/16 - The Department of Education’s proposed new regulation regarding student loans is getting a lot of attention. It received almost 7,000 public comments on proposed changes to how it administers its Federal Direct Loan Program and its requirements for post-secondary schools whose students pay for tuition using federally funded student loans. Unfortunately, ED has not done its homework. Our comment on the proposed rule finds that is likely to create more problems than it solves. This rule could end up hurting the poor and costing taxpayers up to $4.23 billion per year.