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 by GW Regulatory Studies Center scholars.


"Your input and expertise during the drafting of the Early Participation in Regulations Act of 2019 and SMART Act of 2019 was invaluable."

Senator Kyrsten Sinema (D-AZ)
Senator James Lankford (R-OK)

Joint statement


Are Future Lives Worth More, Today, Than Our Own – Simply Because of Income Growth?

The charge questions that EPA has presented to the EEAC for consideration this week relate to the analytical foundations of a procedure for estimating the value of statistical lives saved in the future – possibly the distant future – as a result of regulations imposed today.

Oversight of the Renewable Fuel Standard

Prepared statement for the record for the U.S. Senate Environment and Public Works Committee Hearing on Oversight of the Renewable Fuel Standard

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

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.

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

On May 3, 2011, EPA determined that regulation of hazardous air pollutants (HAP) from coal- and oil-fired electric utility steam generating units (EGUs) was appropriate and necessary, and proposed “mercury and air toxics standards” (MATS) pursuant to section 112 of the Clean Air Act (CAA). The agency issued final MATS on February 16, 2012.

OMB's 2015 Draft Report to Congress on the Benefits and Costs of Federal Regulations

Pursuant to the Regulatory Right-to-Know Act, the Office of Management and Budget (OMB) submits to Congress each year an accounting statement and associated report providing estimates of the total annual benefits and costs of federal regulations; an analysis of impacts of Federal regulation on State, local, and tribal government, small business, wages, and economic growth; and recommendations for reform.

EPA and NHTSA's Proposed Rule: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles – Phase 2

In response to a directive from President Obama, and using their respective statutory authorities, the Environmental Protection Agency (EPA) and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) have jointly proposed a set of standards to regulate greenhouse gas emissions and (almost equivalently) fuel efficiency for medium and heavy-duty engines and vehicles.

A Review of Regulatory Reform Proposals

Testimony before the United States Senate Homeland Security & Government Affairs Committee.

NRC's Financial Qualifications for Reactor Licensing

In June 2015, the Nuclear Regulatory Commission sought public comment on a draft regulatory basis for a proposed rulemaking to amend the financial qualifications standard for new reactor licensing from the current “reasonable assurance” to the proposed “appears to be financially qualified.” I appreciate the opportunity to comment and encourage NRC to proceed with the proposed rulemaking.

EPA's Proposed Renewable Fuel Standards for 2014, 2015, and 2016

As a part of its Renewable Fuel Standard (RFS) program, the Environmental Protection Agency is proposing biofuel blending targets for 2014, 2015, and 2016. The RFS requires refiners to blend specific amounts of renewable fuels into transportation fuel, such as gasoline and diesel.

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

Testimony before the United States Senate Committee on the Budget and the Senate Committee on Homeland Security and Government Affairs' hearing on Accounting for the True Cost of Regulation: Exploring the Possibility of a Regulatory Budget.