Symposium: Reflections on Executive Order 13,422: Introductory Comment
8 Pages Posted: 20 Nov 2011 Last revised: 21 Jul 2013
Date Written: January 1, 2008
This comment argues that much of the immediate controversy over the 2007 executive order expanding Office of Management and Budget review of agency rulemaking activity and guidance documents was rooted in debate over longstanding issues. These longstanding issues included: 1) the proper extent of presidential authority over the administrative process; 2) the tension between agency expertise and agency accountability; 3) the merits of imposing additional procedural requirements on the rulemaking process; and 4) the utility of cost-benefit analysis in improving policy decisions. When placed in this context, the intensity of the immediate controversy over the 2007 executive order makes greater sense.
Keywords: Administrative law, regulatory review, presidency
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