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B-163628 1 (1981-03-24)

handle is hein.gao/gaobabjzn0001 and id is 1 raw text is: COMPTROLLER GENERAL OF THE UNITED STATES WASHINGTON D.C. 20548 B-163628 March 4, 1981 The Honorable Peter W. Rodino, Jr. Chairman, Committee on the Judiciary House of Representatives Dear Mr. Chairman: We appreciate the opportunity to( mmenson H.R. 746, the Regulatory Procedures Act of 1981. As you know, we provided testimony and bill comments last year on H.R. 3263, the pred- ecessor to the current bill, and we are pleased to note that our suggestion for an explicit GAO oversight role was incor- porate in H.R. 3263, as reported, as well as in the current bill. The GAO strongly supports the general thrust of this 'bill that regulatory agencies should carefully and comprehen- sively evaluate the effects of proposed and existing rules as has been required for executive agencies by Executive Order 12291. We do, however, want to make a number of specific sug- gestions for improving this bill. LExecutive Order12044, promulgated under President Carter and Executive Order 12291, which is more restrictive, both re- quire that agencies perform detailed analyses of proposed major regulations., We anticipate a lively debate over just how re- strictive and how detailed those analyses should be. We hope that Congress does not lose sight of one underlying problem, however. iWhile we all support better information and analysis for decisilonmaking, we are dealing here with the highly inexact science of estimating regulatory impacts, and information and analysis are not free. 'The Senate is already required , under Senate Rule 27.6(to specify the regulatory impact of all reported legislation. To assist the Senate in discharging this responsibility, this Of- fice has issued A Technical Guide To Assessing and Preparing Economic Impact Analyses of Regulatory Legislation (PAD-81-03), a copy of which is enclosed. As the report states, Preparing an estimate of the economic impact of regulatory legislation is, of necessity, a very complex exercise . . . . Although interested parties may devoutly wish that a short and easy approach exists to obtain cost estimates, such is not the case. Even when done with sufficient skill and compre- hensiveness, a full scale economic impact analysis may be wide of the mark. .

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