Regulations.gov form for submitting deregulation ideas

There is now a form on Regulations.gov for submitting deregulation ideas in response to last week's OMB RFI. A few observations:

1. The form seems designed to support automated generation of draft Federal Register proposed and final rules through AI-augmented document assembly. The structure of the form roughly follows the structure of a proposed or final rule. It also includes instructions that clearly come from guidance to writers of Federal Register rules. (They forgot to take out this line: "If this is a final rule, you should respond to any relevant and timely comments.")
2. In addition to substantive analysis, the form invites users to submit procedural metadata, such as the name and title of the agency head and the agency address. This supports the auto-generation theory. It also suggests that processing of submissions will be handled by technologists in a process outside the ordinary federal rulemaking ecosystem.
3. The form provides suggested reasons for rescission, which "include, but are not limited to: (1) the regulation is inconsistent with a statute; (2) the regulation is inconsistent with the Constitution; (3) the regulation’s costs outweigh its benefits; (4) the regulation no longer reflects the current state of technology; or (5) the regulation is bad policy, unreasoned, or unsound."

I've previously observed that staffing disruptions could limit how much deregulation the Administration could accomplish under EO 14219. This form appears to be one component of the Administration's strategy to overcome that obstacle.

If I am right about the AI plan, its success will depend a lot on the quality of the responses to the RFI.