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PAD-80-37 1 (1980-01-07)

handle is hein.gao/gaobababz0001 and id is 1 raw text is: COMPTROLLER GENERAL OF THE UNITED STATES WAHNTKD.C. 111251 3-163628 January 7, 1980 The Honorable Peter W. Rodino, Jr. Chairman, Comiittee on the \ U Judiciary 111213 House of Representatives Dear Mr. Chairman: This letter is in response to your request for our omments on d.R. 32637 the Regulation Reform Act of 1979. QSince we iave alread 7'testified on this bill before the Suocommittee on Administrative Law and Government Relations, this letter will be confined to specific suggestions we have for amending the oill. The GAO strongly supports the general thrust of this bill that regulatory agencies snould carefully and comprehensively evaluate the effects of proposed and existing rules as has been required for executive agencies by Executive Order 12044. 'Ne do, however, want to make a numner of specific suggestions for improving this oil 'A DEFINITION OF A MAJOR RULE Title I requires regulatory analyses of every rule defined as major. The definition of a major rule, however, needs to be clarified. Section 601 defines a major rule as one that is likely to result in an effect on the economy of at least $100 y million. Additionally, the oill accounts for the problen of differential impact oy providing as an alternative standard to the $100 million threshold that a rule is major if it will cause a suostantial cnange in costs or prices for individual indus- tries, geographic regions, or levels of government. Tne Dill provides that a najor rule is also any rule that an agency otherwise determines will have a major impact. It is not clear wny tne nonetary standard is set at $100 million except that this is the amount tnat was useJ in Execu- tive OrJer 12044. $100 million may oe too nigh or not nigh enough. Jr, more importantly, it mLay oe tnat no single Jollar figure is appropriate and the purposes of tile legislation -nay be served just as well by using qualitative standards. Indeed, tne Office of Manage nent and 3udget, which nas nonitered com- pliance with Executive drder 12044, commented in its report, 6AD--37 • I

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