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PAD-78-85 1 (1978-10-04)

handle is hein.gao/gaobabacb0001 and id is 1 raw text is: COVPTROLLER GENERAL OF THE UNITED STATES Lw - WASHINGTON DC 20545 V B-170612 B-139310 / The Hon6rable Abraham Ribicoff I Chairman, Senate Committee on 0 Govetnment Affairs United States Senate 111227 Dear Chairman Ribicoff: This letter responds to your request of August 29, 1978, for comments on S.3262, the Regulatory Cost Reduction Act of -978. This bill Vroposes to establish a procedure to reduce the costs of*ompliance with rules and regulations of Feaeral executive departments and independent agencies. The goal is to achieve a 25 percent cost reduction in five years. ..7The bill would require from each executive department and independent agency annual reports which would include the following information: an estimate of the cost of compliance with each rule and regulation, present and proposed; a description of actions taken in the previous year and planned for the next year to reduce these costs; and an explanation of any failures to reduce these costs by 5 percent per year. We support the ob3ective of the bill to reduce the costs of compliance with Federal rules and regulations. Recommendations included in Section 5, such as the simplification of Government forms, the replacement of design standards with performance standards, and the use of market incentives in lieu of rules or regulations, are likely to be useful in accomplish2ng that end. -4C We have several concerns, however, about the bill. The prescribed method of reducing regulatory costs may ne inefficient both because the bill does not take into account regulatory benefits and because the implementation costs of the bill will likely be high. The bill imposes evaluation requiremerts that may exceed the current state of the art. It is concerned only with compliance costs and does not mention other important costs of regulation which we feel should be considered Some provisions appear ambiguous, others seem to require unnecessary annual repetition of work And, the bill places substantial ne4 buraens on a large number of executive departments and agencies PAD-78-85

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