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March 20, 2012 

Administration Should Take Its Own Advice: Imposing Unnecessary Burdens on Agencies Doesn’t Improve Rulemaking

Statement of Amit Narang, Regulatory Policy Advocate, Public Citizen’s Congress Watch Division

With the Office of Information and Regulatory Affairs’ (OIRA) directive to agencies to analyze the cumulative effects of new regulatory standards, Cass Sunstein is figuratively taking a page out of the anti-regulatory playbook by adopting one of the key features of the Regulatory Accountability Act (HR 3010, S. 1909), a piece of legislation that is publicly opposed by the Administration because it ‘would impose unnecessary new procedures on agencies … and impede the ability of agencies to provide the public with basic public protections.’

Unfortunately, the cumulative effects memo from OIRA does in fact impose unnecessary new procedures on agencies, reinforces the false claim that regulations cost jobs, and distorts the crucial role that public protections play in improving and safeguarding the lives of Americans.


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