Tell OMB To Crack Down on Dark Money Fake Front Groups

I used to work at OIRA, the division of the Office of Management and Budget that oversees all domestic regulations. Now they are asking for comments on a new set of standards for the way their review the regulations from administrative agencies like the Cabinet departments and EPA, and from independent commissions like the SEC and FCC. I have been increasingly concerned about the hijacking of the notice and comment process, the system for allowing regulators to publish drafts to get comments from affected parties and then incorporate those comments in the final rule. There are now dozens, maybe hundreds of fake, dark money-funded front groups that are distorting, disrupting, and undermining the system and I’ve filed my own comment to ask OIRA/OMB to address that issue. If you agree, you can file your own comment here. It does not have to be fancy! Just copy some of what I wrote or say: Tell commenters to be honest about where they (and their funding) is coming from.

May 17, 2023

Hon. Richard Revesz
Administrator
Office of Information and Regulatory Affairs

U.S. Office of Management and Budget

725 17th St NW

Washington, D.C. 20053

Re: Re: OMB–2022–0014

Dear Administrator Revesz:

I am an OIRA alum. I was there almost from the beginning, arriving in 1981, when Jim Miller was heading the office. I had come from EPA, where I learned a lot about notice-and-comment regulation, including the conflicts that arose from failure to coordinate between agencies. I recall there was one toxic substance that was regulated separately and often inconsistently depending on whether it was being transported on the highways, transported by trains, exposed to people in the workplace, exposed to people at home through consumer products, or being left in garbage dumps. I also saw the wide disparity in application of cost-benefit analysis and access to the best examples in categories like performance standards vs. design standards, failure to comply with the…