SUMMARY OF CEI COMMENTS: CEI’s comments cover the following four areas.
Consumers’ Right to Know: CEI has long advocated the consumer’s “Regulatory Right to Know.” Consumers benefit from information that helps them understand how regulations affect them personally. To that end, OIRA’s report should provide cost information in a format that makes it comprehensible to consumers.
Department and Agency Assumptions: Congress mandated that OIRA provide an independent report on the costs and benefits of federal regulations. For this report, OIRA uses department/agency estimates, which contain department/agency biases and are not consistent between departments. In addition to working with agencies to standardize and improve procedures, OIRA’s report should attempt to adjust figures to make them more suitable for cross-departmental comparisons.
Regulatory Impacts: One of CEI’s key programs is our “Death by Regulation” project. With this project, we point out that, while a regulation may be designed to help people, it can also have adverse impacts. Currently agencies evaluate the cost to business for compliance, but they do not seem to make an effort to evaluate whether the regulations themselves might produce adverse consequences. Those consequences should be weighed against the benefits portion of the regulatory impact analysis along with other costs.
Recommendations for Review: Following the general comments offered in this letter, CEI analysts answer OIRA’s call for suggestions on ways to improve existing agency regulations.