On the recordMarch 1, 2017
Mr. Chairman, I yield myself the balance of my time. I just want to simply point out that the bill does extend OIRA to review independent agencies. I also would point out, as I did earlier, the Administrative Conference of the United States recommended OIRA review be extended to independent agencies back in 1988. In fact, the American Bar Association recommended OIRA review be extended to independent agencies in 1990 and reaffirmed the need again in 2016. They said: ``We strongly urge you to bring the independent regulatory commissions within the requirements for cost-benefit analysis''--I am going to just inject my own words here in the middle. Cost-benefit analysis, isn't that something reasonable that we should all look at? That is not asking an agency too much, especially if they already have the information. They went on to say: ``OMB review, and retrospective review of rules currently reflected in Executive Order 12866. . . . `' Those are not overly burdensome requests. In fact, in 2011, Sally Katzen, the OIRA Administrator under President Clinton, urged Congress to support extending OIRA review to independent agencies, when she wrote: ``Our concern is that independent agencies are not typically engaging in the analysis that has come to be expected as a form of governmental best practice for regulatory agencies.'' It seems like a reasonable expectation to employ best practices.…





