Using Comments as Data for Research
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Publications
The GW Regulatory Studies Center scholars regularly conduct applied research to understand regulatory policy and practice from a public interest perspective. Our content often takes the form of public interest comments, formal testimony, working papers, policy insights, and short commentaries analyzing the most pressing issues in regulatory policy. View the rest of our material by the different types of publications listed on this page or our research areas.
What We Publish
Journal Articles & Working Papers
Long-form publications intended for academic audiences that take a deep dive into a particular aspect of regulatory policy.
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.
Commentaries & Insights
Short-form publications intended for all audiences which provide easy to access analysis of regulatory policy.
Books & Reports
Formal publications, often completed with other leading organizations and individuals, providing a thorough understanding of regulations and the rulemaking process.
Newsletters
The weekly Regulation Digest contains everything you need to know about regulatory policy today, and our monthly Center Update gives you all of the latest from our team.
For accessible charts and supporting data that you can use in your own publications or presentations, visit the Reg Stats page.
Latest Publications
DOT's Proposed Rule for Air Travel with Service Animals
The Department of Transportation (DOT) is proposing amendments to its Air Carrier Access Act regulation on the transportation of service animals by air. Multiple parties from a variety of perspectives have called for greater regulatory clarity on what qualifies as a service animal, how airlines should classify emotional support animals (ESAs) for air travel, whether uncommon species should be allowed aboard planes, and how to mitigate health and safety risks caused by animal behavior.
FDA & USDA Food Identity Standards
Both FDA and USDA promulgate food identity standards that require foods sold under particular names to have certain characteristics or ingredients that consumers might expect. In 2005, the agencies jointly proposed a rule to establish general principles for evaluating food identity standards.
Reply Comment on Benefit-Cost Analysis at the STB
On November 4, 2019, the STB solicited further information from the public about specific methods that could be used for benefit-cost analysis of rules related to economic regulation of freight railroads.
Are Future Lives Worth More Than Our Own?
The Environmental Protection Agency has asked its Environmental Economics Advisory Committee (EEAC) for advice on how the Agency should adjust the value of statistical lives (VSL) in the future. Incomes in the future are expected to grow, and people with higher incomes tend to place a higher value on measures to reduce their own mortality risks. Does this mean that a benefit-cost analysis should place greater weight on lives saved in the future than it does on those saved today? In comments filed with the Committee and summarized here, Mannix argues that this is more than just a question of analytical technique.
The Council on Environmental Quality (CEQ) is proposing an update to its regulations for implementing the procedural provisions of the National Environmental Policy Act (NEPA) of 1969. The purposes of NEPA include establishing a national policy toward the environment and promoting “efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man.”
Statutory Delegation, Agency Authority, and the Asymmetry of Impact Analysis
This paper documents the diverse degrees of discretionary authority Congress grants US executive branch agencies. It then presents a case study that systematically compares the quality of impact analysis that informed legislative and regulatory decisions on positive train control, a technology mandated by statute in 2008.