Week in Regulation

The Biggest Week on Record

The American Action Forum’s (AAF) “Week in Regulation” series dates back just over 13 years. There has never been a week quite like this across that span. Thanks primarily to the Environmental Protection Agency’s (EPA) latest tailpipe emissions rule for passenger vehicles, Biden Administration regulatory costs have crossed into trillion-dollar (with a T) territory. With 20 rulemakings containing some quantified economic impact, however, the EPA rule was hardly the only story of the week. Across all rulemakings, agencies published $875.3 billion in total costs and added 4.7 million annual paperwork burden hours.


  • Proposed Rules: 36
  • Final Rules: 59
  • 2024 Total Pages: 29,204
  • 2024 Final Rule Costs: $926.3 billion
  • 2024 Proposed Rule Costs: $34.3 billion


The most consequential rulemaking of the week was, far and away, the aforementioned EPA rule on “Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles.” The rule was not necessarily a surprise though, having been released roughly one month ago but only officially hitting the Federal Register this past week. The total costs (utilizing the Biden Administration’s updated discount rate of 2 percent) come out to $870 billion across a 23-year analytic window[1]. As noted by AAF upon its release last month, this discount-rate change results in sizable increases compared to the cost estimate utilizing the more traditional 7 percent, but critically, also results in a higher net-benefits estimate – representing the most high-profile example of such a dynamic yet. The rule will, justifiably, continue to command a considerable amount of political attention. There was a failed Senate vote on EPA’s ability to implement it taken on the very day of its Federal Register publication and it is merely a matter of when, not if, resolutions of disapproval under the Congressional Review Act follow.

As alluded to earlier, there were some other significant actions published this past week. For one, the Department of Energy (DOE) published its latest round of efficiency standards for “General Service Lamps.” DOE expects the updated standards to result in total “Incremental Product Costs” of $2.9 billion. The other member of this week’s Billion-Dollar Rule Club was the Department of Labor’s (DOL) latest rule on “Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” Silica exposure standards have a long-winding rulemaking history, going back to 2003. This particular rule “is lowering its existing exposure limits for quartz or respirable crystalline silica to 50 µg/m3 and setting an action level of 25 μg/m3 for all miners.” DOL estimates that will result in roughly $92 million in annualized costs, or $1.3 billion in present value across the 60-year analysis period the agency utilizes.


As we have already seen from executive orders and memos, the Biden Administration will surely provide plenty of contrasts with the Trump Administration on the regulatory front. And while there is a general expectation that the current administration will seek to broadly restore Obama-esque regulatory actions, there will also be areas where it charts its own course. Since the AAF RegRodeo data extend back to 2005, it is possible to provide weekly updates on how the top-level trends of President Biden’s regulatory record track with those of his two most recent predecessors. The following table provides the cumulative totals of final rules containing some quantified economic impact from each administration through this point in their respective terms.This past week’s regulatory haul has pushed the Biden Administration’s final rule cost tally into truly uncharted territory. That total is now measured in the trillions of dollars after roughly $875 billion in new costs from last week’s final rules. It was one thing, as AAF has noted in recent weeks, for the current administration to surpass the first-term total for the Obama Administration. This past week’s total alone, however, nearly matched the entire Obama presidency. For perspective, if “Biden Administration Regulatory Costs” were a country, its gross domestic product would rank 17th in the world, just behind Indonesia.

Neither of the other two administrations covered here had much to report for mid-April of 2020 and 2012. Each had only nominal cost and paperwork increases measured in the tens of millions of dollars and thousands of hours, respectively.


Since January 1, the federal government has published $960.6 billion in total net costs (with $926.3 billion in new costs from finalized rules) and 13.9 million hours of net annual paperwork burden increases (with 10.2 million hours in reductions coming from final rules).

[1] AAF is maintaining the same methodology it used when recording the cost estimate from the rule’s proposed version into RegRodeo. For further details see the explanation given in that edition of the “Week in Regulation.”


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