Susan E Dudley
Biographic Data
| ID | 4398766 |
|---|---|
| NAME | Susan E Dudley |
| GIVEN NAMES | Susan E |
| FAMILY NAME | Dudley |
| SIGNATURE | DUDLEY S E |
| AFFILIATIONS | George Washington University |
| ORCID | 0000-0002-2686-4283 |
| VERIFIED | Yes |
| TOTAL WORKS | 15 |
| TOTAL CITATIONS | 41 |
| AUTHOR COUNT | 15 |
| EDITOR COUNT | 0 |
| FIRST PUBLICATION YEAR | 2015 |
| LATEST PUBLICATION YEAR | 2025 |
| H-INDEX | 4 |
Ensuring Durability and Objectivity in Regulatory Analysis: Comments on OMB Circular A-4
This article is based on feedback I submitted in response to the Office of Management and Budget’s (OMB’s) April 2023 request for comments on its draft revisions to Circular A-4, “Regulatory Analysis.” Much has changed since I submitted my comments in June 2023. OMB issued a final circular in November 2023 and subsequently rescinded it in February 2025. This article includes my comments as submitted, along with an introductory “prologue” and an “…
Letter from Former SBCA Presidents and JBCA Editors to Oira Administrator
Regulatory Impact Analysis Guidelines: Introduction to Special Issue
This article provides a brief Introduction to this special Journal of Benefit–Cost Analysis issue dedicated to comments filed by former presidents of the Society for Benefit Cost Analysis and editors of this journal on the Office of Management and Budget’s draft Circular A–4 on regulatory impact analysis guidelines
Introduction to the Special Issue
This special issue of the Journal of Benefit–Cost Analysis is dedicated to the memory of Jerry Ellig, a brilliant economist whose untimely death in 2021 cut short a productive and influential career in government and academia. Jerry was adept at applying economic concepts and empirical analysis to improve public policy, and he enjoyed not only studying real policy problems, but finding practical solutions to them. He was also a generous mentor, s…
Regulatory Reform: Results and Challenges
Over the last century, the United States has witnessed three approaches to achieving better regulatory outcomes: the removal of “economic” regulations in certain sectors; regulatory impact analysis (RIA) of new “social” regulations; and retrospective analysis of existing regulations. This article reviews the rationale for each approach, the results to date, and the remaining challenges. It finds that both institutional and technical factors influ…
Nudging the nudger: Toward a choice architecture for regulators
Behavioral research has shown that individuals do not always behave in ways that match textbook definitions of rationality but are subject to cognitive biases that may lead to systematic errors in judgments and decisions. Recognizing that regulators are not immune from these cognitive irrationalities, this article explores how the institutional framework or “choice architecture” in which they operate interacts with those biases. By examining five…
The Office of Information and Regulatory Affairs and the durability of regulatory oversight in the United States
The U.S. Office of Information and Regulatory Affairs (OIRA) is responsible for reviewing executive branch agencies' draft proposed and final regulations, coordinating the federal government's regulatory agenda, approving government collections of information from the public, and developing and overseeing the implementation of government‐wide policies related to information policy, information quality, peer review, privacy, statistical policy, an…
Milestones in the Evolution of the Administrative State
The modern administrative state, as measured by the number of agencies, their budgets and staffing, and the number of regulations they issue, has grown significantly over the last hundred years. This essay reviews the origins of the administrative state and identifies four milestone efforts to hold it accountable to the American people: passage of the Administrative Procedure Act in 1946, the economic deregulation of the 1970s and 1980s, requirem…
Regulatory Oversight and Benefit-Cost Analysis: A Historical Perspective
The Office of Information and Regulatory Affairs (OIRA) in the Executive Office of the President coordinates the federal government’s regulatory agenda, reviews executive branch agencies’ draft regulations, and oversees government-wide information quality, peer review, privacy, and statistical policies. Remarkably, its regulatory oversight functions, and the benefit-cost framework underlying them, have not changed significantly through six very d…
Dynamic Benefit-Cost Analysis for Uncertain Futures
“Uncertain futures” refers to a set of policy problems that possess some combination of the following characteristics: (i) they potentially cause irreversible changes; (ii) they are widespread, so that policy responses may make sense only on a global scale; (iii) network effects are difficult to understand and may amplify (or moderate) consequences; (iv) time horizons are long; and (v) the likelihood of catastrophic outcomes is unknown or even un…
Designing a Choice Architecture for Regulators
The emergence of behavioral public administration has led to increasing calls for public managers and policy makers to consider predictable cognitive biases when regulating individual behaviors or market transactions. Recognizing that cognitive biases can also affect the regulators themselves, this article attempts to understand how the institutional environment in which regulators operate interacts with their cognitive biases. In other words, to…
Consumer’s Guide to Regulatory Impact Analysis: Ten Tips for Being an Informed Policymaker
Regulatory impact analyses (RIAs) weigh the benefits of regulations against the burdens they impose and are invaluable tools for informing decision makers. We offer 10 tips for nonspecialist policymakers and interested stakeholders who will be reading RIAs as consumers. 1. Core problem: Determine whether the RIA identifies the core problem (compelling public need) the regulation is intended to address. 2. Alternatives: Look for an objective, poli…
The role of transparency in regulatory governance: Comparing US and EU regulatory systems
The United States and European Union have focused on improving the practices used to develop and implement legal requirements as a way to improve the quality of regulations themselves. Transparency in the regulatory process, from determining regulatory goals, to evaluating alternative means to achieve those goals, to enforcing regulatory requirements, features high on the agenda of cross-cutting government reform programs that address the issue o…
Please Don't Regulate My Internalities
Employing the Kaldor-Hicks criterion (Boardman et al., 2011, p. 32), benefit-cost analysis poses the question: Would the people who support a particular policy be willing to pay an amount of money sufficient to induce all of those people who oppose that policy to change their votes and thereby achieve unanimous consent? The compensation is hypothetical, of course, as is the voting; but this thought-experiment provides a framework in which to weig…
The Limits of Irrationality as a Rationale for Regulation
If men were angels, no government would be necessary. If angels were to govern men, neither external nor internal controls on government would be necessary. In framing a government which is to be administered by men over men, the great difficulty lies in this: you must first enable the government to control the governed; and in the next place oblige it to control itself
Nudging the nudger: Toward a choice architecture for regulators
Behavioral research has shown that individuals do not always behave in ways that match textbook definitions of rationality but are subject to cognitive biases that may lead to systematic errors in judgments and decisions. Recognizing that regulators are not immune from these cognitive irrationalities, this article explores how the institutional framework or “choice architecture” in which they operate interacts with those biases. By examining five…
The Limits of Irrationality as a Rationale for Regulation
If men were angels, no government would be necessary. If angels were to govern men, neither external nor internal controls on government would be necessary. In framing a government which is to be administered by men over men, the great difficulty lies in this: you must first enable the government to control the governed; and in the next place oblige it to control itself
The Office of Information and Regulatory Affairs and the durability of regulatory oversight in the United States
The U.S. Office of Information and Regulatory Affairs (OIRA) is responsible for reviewing executive branch agencies' draft proposed and final regulations, coordinating the federal government's regulatory agenda, approving government collections of information from the public, and developing and overseeing the implementation of government‐wide policies related to information policy, information quality, peer review, privacy, statistical policy, an…
Consumer’s Guide to Regulatory Impact Analysis: Ten Tips for Being an Informed Policymaker
Regulatory impact analyses (RIAs) weigh the benefits of regulations against the burdens they impose and are invaluable tools for informing decision makers. We offer 10 tips for nonspecialist policymakers and interested stakeholders who will be reading RIAs as consumers. 1. Core problem: Determine whether the RIA identifies the core problem (compelling public need) the regulation is intended to address. 2. Alternatives: Look for an objective, poli…
Milestones in the Evolution of the Administrative State
The modern administrative state, as measured by the number of agencies, their budgets and staffing, and the number of regulations they issue, has grown significantly over the last hundred years. This essay reviews the origins of the administrative state and identifies four milestone efforts to hold it accountable to the American people: passage of the Administrative Procedure Act in 1946, the economic deregulation of the 1970s and 1980s, requirem…
Regulatory Oversight and Benefit-Cost Analysis: A Historical Perspective
The Office of Information and Regulatory Affairs (OIRA) in the Executive Office of the President coordinates the federal government’s regulatory agenda, reviews executive branch agencies’ draft regulations, and oversees government-wide information quality, peer review, privacy, and statistical policies. Remarkably, its regulatory oversight functions, and the benefit-cost framework underlying them, have not changed significantly through six very d…
Dynamic Benefit-Cost Analysis for Uncertain Futures
“Uncertain futures” refers to a set of policy problems that possess some combination of the following characteristics: (i) they potentially cause irreversible changes; (ii) they are widespread, so that policy responses may make sense only on a global scale; (iii) network effects are difficult to understand and may amplify (or moderate) consequences; (iv) time horizons are long; and (v) the likelihood of catastrophic outcomes is unknown or even un…
Please Don't Regulate My Internalities
Employing the Kaldor-Hicks criterion (Boardman et al., 2011, p. 32), benefit-cost analysis poses the question: Would the people who support a particular policy be willing to pay an amount of money sufficient to induce all of those people who oppose that policy to change their votes and thereby achieve unanimous consent? The compensation is hypothetical, of course, as is the voting; but this thought-experiment provides a framework in which to weig…
The role of transparency in regulatory governance: Comparing US and EU regulatory systems
The United States and European Union have focused on improving the practices used to develop and implement legal requirements as a way to improve the quality of regulations themselves. Transparency in the regulatory process, from determining regulatory goals, to evaluating alternative means to achieve those goals, to enforcing regulatory requirements, features high on the agenda of cross-cutting government reform programs that address the issue o…
Please Don't Regulate My Internalities
Employing the Kaldor-Hicks criterion (Boardman et al., 2011, p. 32), benefit-cost analysis poses the question: Would the people who support a particular policy be willing to pay an amount of money sufficient to induce all of those people who oppose that policy to change their votes and thereby achieve unanimous consent? The compensation is hypothetical, of course, as is the voting; but this thought-experiment provides a framework in which to weig…
The Limits of Irrationality as a Rationale for Regulation
If men were angels, no government would be necessary. If angels were to govern men, neither external nor internal controls on government would be necessary. In framing a government which is to be administered by men over men, the great difficulty lies in this: you must first enable the government to control the governed; and in the next place oblige it to control itself
Consumer’s Guide to Regulatory Impact Analysis: Ten Tips for Being an Informed Policymaker
Regulatory impact analyses (RIAs) weigh the benefits of regulations against the burdens they impose and are invaluable tools for informing decision makers. We offer 10 tips for nonspecialist policymakers and interested stakeholders who will be reading RIAs as consumers. 1. Core problem: Determine whether the RIA identifies the core problem (compelling public need) the regulation is intended to address. 2. Alternatives: Look for an objective, poli…
Dynamic Benefit-Cost Analysis for Uncertain Futures
“Uncertain futures” refers to a set of policy problems that possess some combination of the following characteristics: (i) they potentially cause irreversible changes; (ii) they are widespread, so that policy responses may make sense only on a global scale; (iii) network effects are difficult to understand and may amplify (or moderate) consequences; (iv) time horizons are long; and (v) the likelihood of catastrophic outcomes is unknown or even un…
Designing a Choice Architecture for Regulators
The emergence of behavioral public administration has led to increasing calls for public managers and policy makers to consider predictable cognitive biases when regulating individual behaviors or market transactions. Recognizing that cognitive biases can also affect the regulators themselves, this article attempts to understand how the institutional environment in which regulators operate interacts with their cognitive biases. In other words, to…
Regulatory Oversight and Benefit-Cost Analysis: A Historical Perspective
The Office of Information and Regulatory Affairs (OIRA) in the Executive Office of the President coordinates the federal government’s regulatory agenda, reviews executive branch agencies’ draft regulations, and oversees government-wide information quality, peer review, privacy, and statistical policies. Remarkably, its regulatory oversight functions, and the benefit-cost framework underlying them, have not changed significantly through six very d…
Milestones in the Evolution of the Administrative State
The modern administrative state, as measured by the number of agencies, their budgets and staffing, and the number of regulations they issue, has grown significantly over the last hundred years. This essay reviews the origins of the administrative state and identifies four milestone efforts to hold it accountable to the American people: passage of the Administrative Procedure Act in 1946, the economic deregulation of the 1970s and 1980s, requirem…
Nudging the nudger: Toward a choice architecture for regulators
Behavioral research has shown that individuals do not always behave in ways that match textbook definitions of rationality but are subject to cognitive biases that may lead to systematic errors in judgments and decisions. Recognizing that regulators are not immune from these cognitive irrationalities, this article explores how the institutional framework or “choice architecture” in which they operate interacts with those biases. By examining five…
The Office of Information and Regulatory Affairs and the durability of regulatory oversight in the United States
The U.S. Office of Information and Regulatory Affairs (OIRA) is responsible for reviewing executive branch agencies' draft proposed and final regulations, coordinating the federal government's regulatory agenda, approving government collections of information from the public, and developing and overseeing the implementation of government‐wide policies related to information policy, information quality, peer review, privacy, statistical policy, an…
Introduction to the Special Issue
This special issue of the Journal of Benefit–Cost Analysis is dedicated to the memory of Jerry Ellig, a brilliant economist whose untimely death in 2021 cut short a productive and influential career in government and academia. Jerry was adept at applying economic concepts and empirical analysis to improve public policy, and he enjoyed not only studying real policy problems, but finding practical solutions to them. He was also a generous mentor, s…
Regulatory Reform: Results and Challenges
Over the last century, the United States has witnessed three approaches to achieving better regulatory outcomes: the removal of “economic” regulations in certain sectors; regulatory impact analysis (RIA) of new “social” regulations; and retrospective analysis of existing regulations. This article reviews the rationale for each approach, the results to date, and the remaining challenges. It finds that both institutional and technical factors influ…
Ensuring Durability and Objectivity in Regulatory Analysis: Comments on OMB Circular A-4
This article is based on feedback I submitted in response to the Office of Management and Budget’s (OMB’s) April 2023 request for comments on its draft revisions to Circular A-4, “Regulatory Analysis.” Much has changed since I submitted my comments in June 2023. OMB issued a final circular in November 2023 and subsequently rescinded it in February 2025. This article includes my comments as submitted, along with an introductory “prologue” and an “…
Letter from Former SBCA Presidents and JBCA Editors to Oira Administrator
Regulatory Impact Analysis Guidelines: Introduction to Special Issue
This article provides a brief Introduction to this special Journal of Benefit–Cost Analysis issue dedicated to comments filed by former presidents of the Society for Benefit Cost Analysis and editors of this journal on the Office of Management and Budget’s draft Circular A–4 on regulatory impact analysis guidelines
Political science (10 works) · Business (8 works) · Law (8 works) · Law (8 works) · Economics (7 works) · Computer Science (6 works) · Psychology (6 works) · Public economics (6 works) · Regulation and Compliance Studies (6 works) · Government (linguistics (5 works)