Sofie E. Miller

Sofie Miller

Senior Policy Analyst
Phone: 202-994-2974
[email protected]

Sofie E. Miller is a Senior Policy Analyst at the George Washington University Regulatory Studies Center, where she analyzes the effects of federal regulations. Her research portfolio includes use of benefit-cost analysis by agencies, retrospective review of existing rules, economic analysis of energy efficiency standards, quantitative analysis of regulatory benefits, and the regressive effects of regulation. Sofie has drawn on this research to submit over twenty public comments to federal agencies on proposed rules spanning a range of issues, including energy and environment and reducing regulatory burdens. Sofie has published articles in academic journals of public policy and administrative law, and has testified before Congress on topics including regulatory reform and DOE’s energy efficiency standards. Sofie has a master’s degree in public policy with a concentration in regulatory policy from the George Washington University.

Sofie E. Miller CV





Testimony before the U.S. Consumer Product Safety Commission, Safety Standard Addressing Blade-Contact Injuries on Table Saws, Sofie E. Miller with Jacob Yarborough, August 9, 2017

Statement for the Record for the U.S. Senate Small Business & Entrepreneurship Committee, Examining How Small Businesses Confront and Shape Regulations, Sofie E. Miller with Daniel R. Pérez, March 19, 2017

Testimony before the U.S. House Energy and Commerce Subcommittee on Energy and Power, Home Appliance Energy Efficiency Standards under the Department of Energy– Stakeholder Perspectives, Sofie E. Miller, June 10, 2016

Testimony before the U.S. House Judiciary Committee Task Force on Executive Outreach, The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy, Sofie E. Miller, May 24, 2016

Statement for the U.S. Senate Environment and Public Works Committee Hearing, Oversight of the Renewable Fuel Standard, Sofie E. Miller, March 2, 2016


Reforming the Energy Policy and Conservation Act: Learning from Experience on Energy Efficiency, a working paper, Sofie E. Miller, June 27, 2017

The Risks of Regulating in the Dark, Sofie E. Miller, Federalist Society Review, Vol. 18, January 18, 2017

One Standard to Rule Them All: The Disparate Impact of Energy Efficiency Regulations, Nudge Theory in Action: Behavioral Design in Policy and Markets, Sofie E. Miller & Brian F. Mannix, Palgrave MacMillan, 2016

The Final Countdown: Projecting Midnight Regulations, Sofie E. Miller & Daniel R. Pérez, July 12, 2016

The Disappearing Benefits of Energy Efficiency, Sofie E. Miller, Regulation, Spring 2016

Regulatory Accretion: Causes and Possible Remedies, Sofie E. Miller & Susan E. Dudley in Administrative Law Review Accord, Volume 67, 98-114, 2016

Learning from Experience: Retrospective Review of Regulations in 2014, a working paper, Sofie E. Miller, November 3, 2015

Whose Benefits Are They, Anyway? Examining the Benefits of Energy Efficiency Rules 2007 – 2014, a working paper, Sofie E. Miller, September 2, 2015

One Discount Rate Fits All? The Regressive Effects of DOE’s Energy Efficiency Rule, Sofie E. Miller, Policy Perspectives, Volume 22, 40-54

Looking Back to Move Ahead, Sofie E. Miller, Regulation, Fall 2014

Regressive Furnace Fans, Sofie E. Miller, Regulation, Spring 2014

Making the Social Cost of Carbon More Social, Sofie E. Miller, Susan E. Dudley, and Brian F. Mannix, Regulation, Winter 2013-2014

EPA’s Retrospective Review of Regulations: Will it Reduce Manufacturing Burdens?, Sofie E. Miller, Engage, Vol. 14 Issue 2, 4-14

Small Farms, Big Costs, Sofie E. Miller & Cassidy B. West, Regulation, Fall 2013

Questioning NHTSA’s ‘Noisy Electric Cars’ Rule, Sofie E. Miller, Regulation, Summer 2013

EPA’s Retrospective Review of Regulations: Will it Reduce Manufacturing Burdens?, a working paper, Sofie E. Miller, May 17, 2013

Crony Environmentalism, Sofie E. Miller, Regulation, Spring 2013


Fall Unified Agenda outlines Progress of "Two-for-One" Reforms, Sofie E. Miller, December 15, 2017

Leave Vehicle-to-Vehicle Communication to Innovators, Not Regulators, Sofie E. Miller, November 14, 2017

The Time is Right for the EPA to Cut Back the Renewable Fuel Mandate, Sofie E. Miller, September 7, 2017

A Glimpse of President Trump’s Deregulatory “Agenda,” Sofie E. Miller, July 21, 2017

Missing Offsets: EPA and DOE Rules May not Comply with One-in-Two-out Executive Order, Sofie E. Miller, July 19, 2017

Spinning Out of Control: The Hidden Costs of Appliance Efficiency Standards, Sofie E. Miller, March 30, 2017

The Devil is in the Details of President Trump’s Regulatory Executive Order, Sofie E. Miller & Susan E. Dudley, February 1, 2017

As a Parting Gift, Obama Administration Releases Final Report on Regulation, Sofie E. Miller, January 3, 2017

President Obama’s Midnight Regulatory Agenda, Sofie E. Miller, November 18, 2016

Regulatory Review in the Land of Lincoln, Sofie E. Miller, October 25, 2016

Pitching Retrospective Review as a Cure for Regulatory Accumulation, Sofie Miller, March 8, 2016

Senate Shows Continuing Interest in Regulatory Reform, Sofie E. Miller, February 3, 2016

Looking Ahead to Regulation in 2016, Sofie E. Miller, January 20, 2016

Evaluating Retrospective Review of Regulations in 2014, Sofie Miller, November 4, 2015

OMB Reports Higher Costs and Lower Benefits in 2015 Draft Report, Sofie Miller, October 21, 2015

The Questionable Benefits of Energy Efficiency Standards, Sofie Miller, September 15, 2015

Learning from the Past: It’s Time to Reevaluate the Renewable Fuel Standards, Sofie Miller, July 28, 2015

Regulatory Action Holding Steady in Spring 2015 Unified Agenda, Sofie Miller, May 22, 2015

In the News

Forbes OpinionSpeaker Ryan's Plan Highlights Regulatory Burdens On Low-Income Households, by Susan E. Dudley & Sofie E. Miller, June 14, 2016

The Hill, Obama to aggressively pursue 2016 regulations agenda, citing Sofie E. Miller & the GW Regulatory Studies Center

Forbes OpinionCompetitive Markets Need A Neutral Referee, Not A Cheerleader, by Susan E. Dudley and Sofie E. Miller, May 16, 2016

Washington PostObama wants regulations to be effective, but agencies are ignoring his orders, study finds, citing Sofie Miller, November 5, 2015

The HillRegulations need retrospective review, by Sofie Miller, November 5, 2015

Bloomberg BNAUse of Advance Rulemaking Notices Sharply Down Across Federal Agencies, Report Says, citing Sofie Miller, June 30, 2015

Washington TimesSoap opera, Act II: Regulators take another run at dishwashers, citing Sofie Miller in the Washington Times, June 17, 2015

The HillRFS hurts the economy, by Sofie Miller in The Hill, June 11, 2015

Morning ConsultEPA Delay Opens Window for RFS Reform, quoting Sofie Miller in Morning Consult, December 12, 2014

Bloomberg BNA, Unified Regulatory Agenda Released Amid Questions About Effectiveness, quoting Sofie Miller in Bloomberg BNA, November 25, 2014

The HillObama Pushes Green Standards for Everything but the Kitchen Sink, citing Sofie Miller in The Hill, August 29, 2014

The HillRyan opens new front in war on poverty, quoting Sofie Miller in The Hill, August 19, 2014


Recent Articles

U.S. Capitol

Examining How Small Businesses Confront and Shape Regulations

March 29, 2017

By Sofie E. Miller & Daniel R. Pérez
On March 29th, the U.S. Senate Committee on Small Business & Entrepreneurship met to consider legislative reforms that would affect how small businesses confront and shape regulations. This prepared statement for the record focuses on S. 584: Small Business Regulatory Flexibility Improvements Act. The analysis suggests that the Committee should: be careful to avoid the problem of double-counting indirect costs, use an evidence-based regulation framework to strengthen retrospective review, and safeguard against unintentionally reducing the efficacy of the existing Small Business Advocacy Review process.

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.


The Risks of Regulating in the Dark

January 18, 2017

By Sofie E. Miller in the Federalist Society Review, Volume 18
“Midnight” regulations are those issued after the November presidential election but before Inauguration Day as the outgoing administration attempts to finalize its regulatory policy priorities with a surge of rulemaking activity. Scholars have theorized that midnight rules are problematic because they short-circuit important procedural safeguards that ensure high-quality regulatory outcomes, like rigorous analysis, internal and external review, and public input in the rulemaking process. Stepping beyond theory, recent examples—such as the Department of Energy’s energy efficiency standards for clothes washers—illustrate that midnight rules impose real burdens.

Google car

Public Comment on NHTSA’s Federal Automated Vehicles Policy: Accelerating the Next Revolution In Roadway Safety

November 16, 2016

By Sofie E. Miller, Howard Beales and Daniel R. Pérez
This comment on the National Highway Traffic Safety Administration’s (NHTSA) recent Federal Automated Vehicles Policy considers the impact of regulating driverless car technology on innovation and social welfare. NHTSA is correct to be cautious of the effects that a federal policy could have on innovation, particularly because the safety gains from highly automated vehicles (HAV) could be significant. As a result, the agency should avoid any type of premarket approval authority for HAV technology, which could potentially delay the adoption of life-saving innovations and result in thousands of traffic fatalities.


Public Comment to the Commission on Evidence-Based Policymaking

November 08, 2016

By Marcus Peacock, Sofie E. Miller and Daniel R. Pérez
Scholars at the GW Regulatory Studies Center show how the U.S. could make regulations more evidence-based in a comment to the Commission on Evidence-Based Policymaking. Evidence-based regulations plan for, collect, and use evidence to predict, evaluate and improve societal outcomes throughout the rule’s life. This comment lays out a process for producing such rules and provides over a dozen specific recommendations on how the U.S. could better adopt and implement such a system.

Nudge Theory

One Standard to Rule Them All: The Disparate Impact of Energy Efficiency Regulations

October 12, 2016

Chapter by Sofie E. Miller and Brian F. Mannix
Federal regulations restrict the energy that everyday products can use, for everything from cars to microwaves. While these rules impose significant costs on consumers, the benefits are harder to identify. Agencies claim that restricting consumers’ choices provides consumers with large benefits, but this reasoning is hard to reconcile with the fact that consumers have many legitimate reasons to prefer the appliances they buy and the cars they drive. This chapter explores the reasoning behind energy efficiency regulations and why these reasons are insufficient to support the large costs they impose on consumers, especially low-income consumers.

Manufactured homes

Public Comment on Energy Conservation Standards for Manufactured Housing

August 16, 2016

By Sofie E. Miller
The Department of Energy’s proposed rule would establish new energy efficiency standards for manufactured housing (formerly known as mobile homes). Due to anticipated price increases, the rule would have a regressive effect on low-income and elderly households, who are the primary occupants of manufactured homes. DOE’s analysis doesn’t take into account resale market obstacles that could prevent homeowners from recouping the higher upfront costs of efficient units, especially in Southern states with high poverty rates that bear the highest costs from the rule.

The Final Countdown Report Cover

The Final Countdown: Projecting Midnight Regulations

July 12, 2016

By Sofie E. Miller and Daniel R. Pérez
The final months of presidential administrations are accompanied by a significant increase in regulatory output as the executive branch relies increasingly on unilateral activity in a rush to implement its remaining policy priorities. This has come to be known as the “midnight period.” This report contains two robust, quantitative models that contribute to the scholarship in this area by: predicting the number of economically significant rules likely to be issued during the Obama administration’s final months, and finding that independent regulatory agencies do not increase their regulatory output during presidential transitions.

Corn field at sunset

Public Comment on EPA’s Proposed Renewable Fuel Standards for 2017 and Biomass-Based Diesel Volume for 2018

July 12, 2016

By Sofie E. Miller
EPA’s latest Renewable Fuel Standard proposal would increase the mandated total renewable fuel production to 18.8 billion gallons in 2017. Although it was intended to improve the environment, availability of new scientific, technical, and economic information shows that the RFS program is likely causing significant environmental harm through increased greenhouse gas emissions and damage to waterbodies and ecosystems. Given the environmental damage and the large economic impact of the standards, EPA should update its benefits analysis and consider using its waiver authority to further reduce the standards.

Department of Energy seal

Public Comment on DOE’s Regulatory Burden Request for Information "Reducing Regulatory Burden"

July 11, 2016

By Sofie E. Miller
To improve its ongoing retrospective review efforts, this public comment recommends that the Department of Energy incorporate plans for retrospective review into its economically significant or major rules, and provide enough time between energy efficiency standards to allow for an effective review of each rule before increasing the stringency of its standards. DOE should also consider surveys or other measures of actual consumer behavior to ensure that its assumptions about household appliance energy use are accurate. Finally, DOE should commit to measuring whether its standards negatively affect competition in regulated industries.

Energy efficiency graph

Home Appliance Energy Efficiency Standards under the Department of Energy– Stakeholder Perspectives

June 10, 2016

By Sofie E. Miller
In testimony before the House Energy and Commerce Subcommittee on Energy and Power, Senior Policy Analyst Sofie E. Miller explains that one-size-fits-all energy efficiency standards can deprive consumers of the ability purchase the appliances that best suit their unique circumstances and constraints. As a result, these regulations cost consumers rather than benefiting them, as the Department of Energy posits. In addition, these standards disparately impact low- and median-income households, and current analyses of their effects suggest that these populations bear significant costs as a result.


The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy

May 24, 2016

By Sofie E. Miller
In testimony before the House Task Force on Executive Overreach, Senior Policy Analyst Sofie E. Miller explains that retrospective review is a key component of an effective regulatory process because it allows agencies to review whether existing rules are accomplishing their intended goals and to determine what effect they have on the regulated public. Miller argues that writing rules at the outset to facilitate this measurement can improve outcomes and enable policymakers to learn from what has worked and what hasn’t.

White House

Public Comment to the National Economic Council on The President's Executive Order 13725: Steps to Increase Competition and Better Inform Consumers and Workers to Support Continued Growth of the American Economy

May 12, 2016

By Sofie E. Miller, Daniel R. Pérez, Susan E. Dudley & Brian Mannix
This public comment suggests several areas of regulatory policy where federal regulations have hindered, rather than helped, competition, and recommends that agencies take this opportunity to reduce these regulatory barriers to competition.

ALR cover

Regulatory Accretion: Causes and Possible Remedies

March 04, 2016

By Sofie E. Miller & Susan E. Dudley
In this response in the ALR Accord to Reeve Bull’s article, "Building a Framework for Governance: Retrospective Review and Rulemaking Petitions," Miller and Dudley address the inadequacy of the current retrospective review regime, examine the key causes of this failure, and address Bull’s proposal to encourage private parties to initiate review via rulemaking petitions. Miller and Dudley conclude that, while public participation is beneficial in retrospective review, agencies themselves could better this process by writing plans for review at the outset and improving regulatory outcomes.

United States Senate Alt Seal

Oversight of the Renewable Fuel Standard

March 02, 2016

By Sofie E. Miller
Since Congress created the Renewable Fuel Standard (RFS) program, new information has become available about the effects of mandated biofuel production indicating that the environmental effects are significant and negative. This invited testimony for the record examines evidence from the existing literature, which finds that biofuel production produces criteria pollutants, damages water systems from crop fertilizer runoff, and may not reduce greenhouse gas emissions relative to gasoline. Given this evidence, Congress should reevaluate the goals of the program and put the program on a sustainable trajectory.