Susan E. Dudley

Susan E. Dudley

Director, Regulatory Studies Center; Distinguished Professor of Practice
Phone: 202-994-7543


Susan Dudley is Director of the George Washington University Regulatory Studies Center, which she established in 2009 to raise awareness of regulations’ effects and improve regulatory policy through research, education, and outreach. She is also a distinguished professor of practice in the Trachtenberg School of Public Policy and Public Administration. She is president of the Society for Benefit Cost Analysis, a senior fellow of the Administrative Conference of the United States, a National Academy of Public Administration Fellow, on the board and the National Federation of Independent Businesses Legal Center, and on the executive committee of the Federalist Society Administrative Law Group. Her book, Regulation: A Primer, with Jerry Brito, is available on
From April 2007 through January 2009, Professor Dudley served as the Presidentially-appointed Administrator of the Office of Information and Regulatory Affairs in the U.S. Office of Management and Budget and was responsible for the review of draft executive branch regulations under Executive Order 12866, the collection of federal-government-wide information under the Paperwork Reduction Act, the development and implementation of government-wide policies in the areas of information policy, privacy, and statistical policy, and international regulatory cooperation efforts.
Prior to OIRA, she directed the Regulatory Studies Program at the Mercatus Center at George Mason University, and taught courses on regulation at the George Mason University School of Law. Earlier in her career, Professor Dudley served as an economist at OIRA, as well as the Environmental Protection Agency and the Commodity Futures Trading Commission. She was also a consultant to government and private clients at Economists Incorporated. She holds a Master of Science degree from the Sloan School of Management at MIT and a Bachelor of Science degree (summa cum laude) in Resource Economics from the University of Massachusetts, Amherst.


Susan E. Dudley CV


Recent Testimonies

Testimony before the U.S. Senate Homeland Security & Governmental Affairs Committee, A Review of Regulatory Reform Proposals, Susan Dudley, September 17, 2015

Testimony before the U.S. Senate joint hearing with the Committee on the Budget and the Homeland Security & Governmental Affairs Committee, Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget, Susan Dudley, June 23, 2015

Testimony before the U.S. Senate Subcommittee on Regulatory Affairs and Federal Management Roundtable Discussion, Examining Practical Solutions to Improve the Federal Regulatory Process, Susan Dudley, June 3, 2015

Recent Commentaries

Evolution and Innovation, Susan E. Dudley, June 14, 2016

President Obama’s Competition Executive Order Could Benefit from a History Lesson, Susan E. Dudley, April 19, 2016

OSHA’s Shortsighted Solution to Crystalline Silica Exposure, Susan E. Dudley, March 30, 2016

Regulatory Reboot: Options for Revisiting Midnight Regulations, Susan E. Dudley, February 23, 2016

Countdown To Midnight On The President's Regulatory Priorities, by Susan E. Dudley, January 26, 2016

The Ozone Charade, Susan E. Dudley, October 28, 2015

EPA’s Ozone Rule and the Scientization of Policy, Susan E. Dudley, October 7, 2015

With Data, Will Regulators Show Humility or Hubris? Susan E. Dudley, September 22, 2015

Considering the Cumulative Effects of Regulation, Susan E. Dudley, August 10, 2015

Supreme Court's EPA Mercury Ruling is a Victory for Common Sense Regulation, Susan E. Dudley, June 30, 2015

Select recent media mentions

Forbes Opinion, Speaker Ryan's Call For Regulatory Humility, by Susan E. Dudley, June 15, 2016

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

The HillReport: Regs spending has increased twentyfold since Eisenhower, citing Susan Dudley & the GW Regulatory Studies Center, May 17, 2016

Bloomberg BNA, The Cost of Federal Regulations? Not Backyard Barbecue Banter, citing Susan Dudley & the GW Regulatory Studies Center, May 17, 2016

Forbes Opinion, From Eisenhower To Obama, This Is How Much Regulatory Spending Has Changed, by Susan Dudley & Melinda Warren, May 17, 2016

Forbes Opinion, Competitive Markets Need A Neutral Referee, Not A Cheerleader, by Susan E. Dudley & Sofie E. Miller, May 16, 2016

Bloomberg BNA, EPA Final Chemical Rules Confront OMB Deadline, citing Susan Dudley, May 4, 2016

Forbes Opinion, Transatlantic Regulatory Trade Needs Both Cooperation And Competition, by Susan E. Dudley, April 26, 2016

Forbes Opinion, Is the Consumer Financial Protection Bureau Unconstitutional? by Susan Dudley, April 15, 2016

Forbes Opinion, Senators Show Bipartisan Support For Evidence-Based Regulation, by Susan Dudley, March 24, 2016

Recent Articles

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.

EU-US Regulatory Cooperation

US-EU Regulatory Cooperation: Lessons and Opportunities

April 26, 2016

By D. Pérez, S. Dudley, N. Eisner, R. Lutter, D. Zorn and N. Nord
The George Washington University Regulatory Studies Center prepared this report as part of a grant from the European Union to analyze regulatory cooperation between the EU and U.S. The report includes three case studies examining how cooperation has worked in practice between U.S. regulatory agencies and their EU counterparts and an analysis of U.S. regulations likely to have significant effects on international trade and investment. These analyses identify opportunities to reduce incompatible approaches while indicating areas where differences could persist due to issues of national sovereignty and structural differences between countries.

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.


Should Federal Regulatory Agencies Report Benefits to Americans from Mandated Reductions in Greenhouse Gas Emissions?

February 09, 2016

By Art Fraas, Randall Lutter, Susan E. Dudley, Ted Gayer, John Graham, Jason F. Shogren, W. Kip Viscusi
In a letter to the National Academy of Sciences on its project, "Assessing Approaches to Updating the Social Cost of Carbon," a group of prominent regulatory economists argues that federal regulatory analysis should compare domestic regulatory benefits to domestic costs. The current government approach of reporting only the global benefits of reducing carbon emissions neglects that duty. The letter recommends that the panel adopt a dual approach that refocuses regulatory impact analysis of climate regulations on domestic benefits, while providing for separate reporting of estimated global benefits.

Supreme Court

Public Comment on EPA’s Proposed Supplemental Finding that it is Appropriate and Necessary to Regulate Hazardous Air Pollutants from Coal- and Oil-Fired EGUs

January 11, 2016

By Susan E. Dudley
EPA fails to show that its MATS is appropriate and necessary to address risks to public health and the environment from hazardous air pollutants. Its preferred approach has methodological problems and does not address the Supreme Court’s direction to balance the harm of the regulation against the good. Its benefit-cost analysis is dominated by co-benefits that are not subject to the statutory authority on which it relies, and that could be addressed more cost-effectively elsewhere. EPA also ignores the fact that the $9.6 billion cost will have large detrimental effects on public health.

OMB seal

Public Comment on OMB’s 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations

December 15, 2015

The Office of Management and Budget’s 2015 Draft Report to Congress provides information on costs and benefits for certain final rules issued between FY 2004 and FY 2014. The Report provides the public valuable information both on estimates of the effects of major executive branch regulations, and also on OMB’s focus and priorities. This comment offers recommendations for improving regulatory impact assessments, writing rules to encourage retrospective review of regulations, and the use of “private benefits” to justify energy efficiency standards.

Dudley testimony

A Review of Regulatory Reform Proposals

September 17, 2015

By Susan E. Dudley, Director
The Senate Homeland Security & Government Affairs Committee held a hearing on Thursday September 16, at which they asked Susan Dudley to provide expert input on six regulatory reform proposals scheduled for markup. Her testimony complimented the Committee on the constructive, bipartisan reforms, which if passed, could bring about real improvements in regulatory procedures and outcomes. She offered detailed comments on each bill, of which three focus on evaluating the effects of existing regulations and modifying them as appropriate, and three focus on enhancing analytical procedures conducted before new regulations are issued.


Regulatory Science and Policy: A Case Study of the National Ambient Air Quality Standards

September 09, 2015

By Susan E. Dudley
Effective environmental policy depends on reliable scientific information and transparent policy choices; it is challenged not only when science is politicized, but also when policy is “scientized.” This paper suggests that current practices scientize policy and threaten not only regulatory outcomes, but the credibility of the scientific process. Using a case study of the procedures by which the Environmental Protection Agency sets National Ambient Air Quality Standards under the Clean Air Act, it illustrates some of the perverse incentives involved in developing regulations, and offers possible mechanisms to improve those incentives and resulting policy.

US and EU flags

The Role of Transparency in Regulatory Governance: Comparing US and EU Regulatory Systems

August 11, 2015

By Susan E. Dudley & Kai Wegrich
This review of regulatory procedures in the EU and US suggests that each values good regulatory practices, such as transparency, public consultation, and regulatory impact analysis, but emphasizes them to different degrees at different stages in the regulatory process. Particularly for regulations that address human health risks, both jurisdictions should be more transparent regarding the uncertainties surrounding estimates of regulatory outcomes and the effect of key assumptions on those estimates. A transparent process for evaluating regulatory effects ex post could also improve regulatory analysis and outcomes.

Pages in the federal register graph

Can Fiscal Budget Concepts Improve Regulation?

July 16, 2015

By Susan E. Dudley
Despite efforts to ensure that new regulations provide net benefits to citizens, the accumulation of regulations threatens economic growth and well-being. As a result, the U.S. legislature is exploring the possibility that applying fiscal budgeting concepts to regulation could bring more accountability and transparency to the regulatory process. This paper examines the advantages and challenges of applying regulatory budgeting practices, and draws some preliminary conclusions based on successful experiences in other countries.

Congress 1941

Improving Regulatory Accountability: Lessons from the Past and Prospects for the Future (as published)

July 15, 2015

By Susan E. Dudley
This Article examines efforts by the three branches of federal government to oversee regulatory policy and procedures. It begins with a review of efforts over the last century to establish appropriate checks and balances on regulations issued by the executive branch and then evaluates current regulatory reforms that would hold the executive branch, the legislative branch, and the judicial branch more accountable for regulations and their outcomes.

Susan Dudley testimony

Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget

June 23, 2015

By Susan E. Dudley, Director
On June 23, RSC scholars Susan Dudley and Richard Pierce and President of the Canadian Treasury Board, Tony Clement, testified during a joint hearing before the U.S. Senate Committee on the Budget and Committee on Homeland Security and Government Affairs. Dudley testified in support of a regulatory budget and cited the potential for constructive debate on the real impacts of regulations, greater transparency, more efficient allocation of resources, and ultimately the potential for more cost-effective achievement of public priorities.

Image of Susan Dudley testifying

Examining Practical Solutions to Improve the Federal Regulatory Process

June 03, 2015

Susan E. Dudley, Director
Though regulation affects every aspect of our lives, as a policy tool it rarely reaches the attention of voters (and consequently of elected officials) because, unlike the federal budget, its effects are often not visible. This testimony offers recommendations in four areas that may meet the Subcommittee's request for "common sense ideas that could garner bipartisan support and provide immediate improvement to the federal regulatory process." These are 1) codifying regulatory impact analysis requirements, 2) providing for earlier analysis and public input on new regulations, 3) increasing resources for regulatory oversight, and 4) being mindful of regulatory consequences when passing new legislation.

Reg Budget report cover

2016 Regulators' Budget: Increases Consistent with Growth in Fiscal Budget

May 19, 2015

By Susan E. Dudley, Director, & Melinda Warren
This report tracks the portion of the Budget of the United States devoted to developing and enforcing federal regulations from 1960 to 2016. It presents the President’s requested budget outlays in fiscal year (FY) 2016, as well as estimated outlays for FY 2015 as reported in the Budget of the United States Government for Fiscal Year 2016. This “regulators’ budget” reflects the on-budget costs of regulation. This report finds that the regulators’ budget is growing at approximately the same pace as the overall Budget, 5.3 percent in real terms in FY 2016 and 4.3 percent in FY 2015. The President’s proposed budget for the regulatory activities tracked here is $66.8 billion in FY 2016; estimated outlays in FY 2015 are $62.4 billion. The Budget also requests increases in federal regulatory agency personnel of 1.2 percent in FY 2016 and 0.2 percent in FY 2015. Staffing at regulatory agencies is expected to exceed 280,500 people in 2016.

JPAM journal cover

Point/Counterpoint: Valuing Internalities in Regulatory Impact Analysis

May 13, 2015

By Brian Mannix & Susan Dudley
In this Point/Counterpoint article series with Cass Sunstein & Hunt Allcott, Mannix & Dudley argue that allowing regulators to control consumers 'for their own good' – based on some deficiency in the consumers themselves rather than any failure in the marketplace – is to abandon any serious attempt to keep regulatory policy grounded in any objective notion of the public good.