Research
June 10, 2015
Administration’s Regulatory Agenda Imposes $110 Billion in Costs
In what has become an unfortunate biannual tradition in failed transparency, the administration released its regulatory agenda on the eve of a holiday weekend, this time, the Thursday evening before Memorial Day. An American Action Forum (AAF) review of the agenda found more than $110 billion in potential costs, with billions more in unknown burdens.
Once again, there are few surprises in the regulatory agenda. The administration listed 18 new “economically significant” regulations, down from 23 in the previous agenda. It appears that August and October will be busy this year. The administration plans to finalize its greenhouse gas standards for new and existing sources, protections for agricultural workers, and food safety measures. By October, the schedule calls for three final energy efficiency standards, produce safety regulation, and a final ozone rule.
The two largest measures are EPA rules for greenhouse gas standards at existing power plants and revised ozone regulations. Currently, final silica standards and fiduciary rules for investment advisors do not have dates for publication. Below, there are approximately 40 notable rulemakings and their scheduled publication dates.
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May 2015 |
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|---|---|---|---|---|
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Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
EPA |
Final |
Definition of Waters of the U.S. |
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|
EPA |
Final |
Underground Storage Tank Rules |
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|
June-July 2015 |
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|---|---|---|---|---|
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Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
Treasury |
Final |
Margin and Capital Requirements |
||
|
EPA |
Proposed |
*Phase 2: GHG Standards for Heavy-Duty Engines, Vehicles |
|
|
|
HHS |
Final |
Regulation on the Sale of Tobacco Products |
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|
Energy |
Proposed |
Conservation Standards: Central Air Conditioners |
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|
|
August 2015 |
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|---|---|---|---|---|
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Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
EPA |
Final |
GHG Guidelines for Existing Sources |
||
|
EPA |
Final |
GHG Guidelines for New Sources |
|
|
|
CFPB |
Final |
Home Mortgage Disclosure |
||
|
HHS |
Final |
Updated Standards for Labeling of Pet Food |
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|
DOL |
Final |
Personal Fall Protection Systems |
||
|
EPA |
Final |
Agricultural Worker Protection Standards |
||
|
HHS |
Final |
Covered Outpatient Drugs |
||
|
FDA |
Final |
Controls for Human Food |
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September 2015 |
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|---|---|---|---|---|
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Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
EPA |
Final |
Effluent Guidelines for Power Plants |
||
|
DOJ |
Final |
Implementation of ADA Amendments |
||
|
October-November 2015 |
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|---|---|---|---|---|
|
Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
HHS |
Final |
Produce Safety Regulation |
||
|
DHS |
Final |
Worker Identification Credential |
||
|
EPA |
Final |
Review of NAAQS for Ozone |
||
|
Energy |
Final |
Conservation Standards: Warm Air Furnaces |
||
|
Energy |
Final |
Conservation Standards: Dishwashers |
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|
Energy |
Final |
Conservation Standards: Air Conditioners |
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|
FDA |
Final |
Verification for Imported Human Food |
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|
EPA |
Final |
Formaldehyde Emissions Standards for Composite Wood Products |
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|
December 2015 |
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|---|---|---|---|---|
|
Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
Energy |
Final |
Conservation Standards: Large Commercial A/C |
||
|
DOL |
Final |
Persuader Agreements |
|
|
|
Treasury |
Final |
Assessment of Fees for Large Banks |
|
|
|
Energy |
Final |
Conservation Standards: Hearth Products |
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|
Energy |
Final |
Conservation Standards: Gas Furnaces |
||
|
January 2016 |
||||
|---|---|---|---|---|
|
Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
DOT |
Final |
Commercial Driver’s License Clearinghouse |
||
|
CFPB |
Final |
Requirements for Prepaid Cards |
||
|
DOL |
Final |
Unified and Combined State Plans |
||
|
Interior |
Final |
Arctic Drilling Regulations |
||
|
March-April 2016 |
||||
|---|---|---|---|---|
|
Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
HHS |
Final |
Revision of Nutrition Labels |
||
|
HHS |
Final |
Sanitary Transportation of Human and Animal Food |
||
|
HHS |
Final |
Serving Sizes of Foods |
||
|
SEC |
Final |
Standards for Covered Clearing Agencies |
||
|
SEC |
Final |
Rules for Security Swap Dealers |
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|
Long-Term |
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|---|---|---|---|---|
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Agency |
Proposed/ Final |
Rule |
RIN |
Cost (in millions) |
|
DOJ |
Final |
ADA Guidelines for Passenger Vessels |
||
|
DOL |
Final |
Exposure to Crystalline Silica |
||
|
DOL |
Final |
Conflict of Interest-Investment Advice |
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Possible Cost: $110.8 Billion
The $110 billion estimate contains just 37 monetized figures and an incredible amount of uncertainty. The public does not yet know the cost of proposed efficiency standards for heavy-duty trucks and engines or the dozens of other major rules without a public cost-benefit analysis. The previous heavy-duty rule cost more than $8 billion. In fact, the new rule is slated for final publication on January of 2017, a “midnight” period for presidents when there has historically been a rush of regulatory activity.
Final costs could balloon or diminish significantly compared to earlier versions. The administration’s time in office is coming to a close, so regulators will surely rush to finish its greenhouse gas and ozone standards before the next administration takes power.
