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RFI on deregulation ideas

BJ Sanford BJ Sanford • April 10, 2025

TLDR: "Are there any regulations you want to repeal?" I guess the White House is unhappy with the volume of regulation repeal ideas coming out of the regulatory review under EO 14219: they're about to ask the public for help. I doubt the Federal Register has ever seen an RFI as short as this one, filed on public inspection and scheduled to be in tomorrow's Federal Register.

Rulemaking & Administrative Procedure

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Regulations.gov form for submitting deregulation ideas

April 14, 2025

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

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EO floats bypass of notice-and-comment for deregulatory actions

April 10, 2025

Major developments re the Deregulation EO 14219, including a plan to bypass notice-and-comment on some regs. A new EO signed yesterday orders agency heads to bypass notice-and-comment if a rule they want to repeal is "in conflict with" one of 10 listed Supreme Court decisions (including Loper Bright and Jarkesy). Agency heads are to prioritize this immediately after the scheduled end of the regulatory review on April 20, invoking the "good cause" exception under the APA. The original EO 14219 ordered a comprehensive review of regulation and guidance under seven factors, four of which...

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