Susan Dudley, Director of The George Washington University Regulatory Studies Center and Administrative Conference Public Member, posted a commentary on the GWU Regulatory Studies Center’s website regarding her testimony at the House Judiciary Committee’s Subcommittee on Courts, Commercial and Administrative Law hearings on Monday, February 28, 2011, regarding the Administrative Procedure Act, which will turn 65 in June.
Ms. Dudley specifically referenced the Administrative Conference in her commentary:
"So, the Subcommittee’s interest in regulatory reform is welcome. There is abundant scholarship on this subject, including the recommendations made over the years by the Administrative Conference of the United States, which recently reconvened. Unlike the scholarship regarding the traditional forms of regulation in the 1970s, the policy literature today does not uniformly support deregulation but rather examines the incentives provided by different forms of regulation and the resulting benefits and costs to society. Witnesses agreed that Congress might consider procedural reforms to engage the public more effectively on agencies’ justifications for new regulations, and to improve judicial review. Applied to the most significant regulations, these process changes could improve the empirical accuracy of factual determinations and the rigor and transparency of agencies’ supporting analysis."