Doing Regulations

GAO has a new report on the rulemaking process. (After a law is enacted, usually the responsible agency within a department has to go through rulemaking to come up with regulations which are legally binding on the public.)

Based on the limited information available, the average time needed to complete a rulemaking across our 16 case-study rules was about 4 years, with a range from about 1 year to nearly 14 years, but there was considerable variation among agencies and rules.

As far as I can see, the focus seems to be on the differences among agencies, the lack of data on the process, and the role of OMB's review body (the one Cass Sunstein is to head). Nothing on the impact, or lack thereof, of new technology and regulation.gov. Note if it takes 4 years to do a reg, a new President doesn't impact regs until he's almost out the door, or reelected. So much for fantasies of how oppressive the government is--we just can't act that fast.

The Military-Industrial Complex in WWII

Stumbled across this site (Pacific War Encylcopedia) via a comment on Volokh.com). Reminds me of my fascination growing up with the navy and WWI and II. Idly surfing it, and trying to exercise willpower, I came on this:

The Alaskas formed the heavyweight tier of a three-tiered cruiser family conceived in 1939 (the other two tiers eventually becoming the Baltimores and the Clevelands.) They were an utterly unnecessary design, doing nothing that an Iowa did not do better, and doing most things much worse; and, at $75 million apiece, they were not that much cheaper than the Iowas. They were originally a response to rumors that the Japanese had something similar in the works, which the Japanese did not.

I'd also cite this bit:

Allied interrogators did not as a rule employ any form of torture. They did not need to. Because the Japanese military code of honor absolutely forbade surrender, Japanese soldiers received no instruction on how to behave in captivity, and those captured felt such shame that they had little psychological resistance to interrogation. Many sang like canaries. However, the fact that officers almost never surrendered meant that almost all prisoners were enlisted men with little or no high-level information to impart.

The Limits of Public Input

According to this Post piece:

Forget about the economic crisis, the wars in Iraq and Afghanistan and saving Social Security: An online opinion survey released by the White House this week ranks legalizing pot, playing online poker and cracking down on Scientologists as far more important issues

It reflects the limits of the public involvement campaign by the Obama administration.

Fun for FSA Offices--Direct Attribution

FSA just issued a notice on cleaning up their computer files which will be used in enforcing direct attribution of payments for payment limitation rules. Unfortunately the 2008 farm bill caught FSA partway through its change from the System/36/AS400 system (minicomputers in each county office communicating nightly with the mainframe in Kansas City) to an Internet-based solution. A problem with the first system which we fought beginning in 1985 with its first implementation is keeping all the data consistent between counties and mainframe (now it's called synchronizing and software packages handle it, then it was called a pain in the a** and it requires human intervention and troubleshooting). And that means you're dependent on everyone doing their job perfectly and no glitches in the process.

As far as I'm concerned, USDA's failure to get FSA's basic farmer and farm data moved completely to the Internet shows Secretaries Glickman, Venneman, Johannes, and Schafer were not good managers. (I'm sure they're all greatly concerned about my lack of regard for them.)

Race and Sex Classification of Farmers

USDA is asking for comments on its collection of race, sex, etc. classification of farmers:

This notice announces the OASCR's intention to
request approval for a new information collection aimed at
standardizing and consolidating the race, ethnicity, sex, national
origin, disability and age (RESNODA) data for agencies within the U.S.
Department of Agriculture (USDA) that serve agricultural producers and
landowners.

This is a result of GAO criticism of USDA's current records, which are based on visual inspection of the farmer.

I plan to write on this some more later. Comments are open through July 13.

The Role of Government

I'm reading a biography of Alfred Sloan (head of GM from 1920's on). Turns out a big controversy then was over safety glass in windshields. Sloan objected, because customers didn't want it, as witness the fact they weren't willing to pay extra for it. (Similar to the 1950's, when Ford (under Robert McNamara) tried to sell a steering wheel with recessed center column, among other safety features, and couldn't.)

Assessing Performance

Obama is proposing changes in the PART (Program Assessment Rating Tool) system for assessing performance according to this Government Executive piece .And this OMB document. Although the words are okay, I reiterate my feeling: the only way for this sort of thing to be really effective is to get Congress to buy in. For example, Obama proposed cutting a number of programs, based partly on their PART scores. But I haven't heard any Democrats or Republicans agree that was a good basis for decisionmaking. It's the appropriators in Congress who have hold of the money, meaning the hearts and minds of the bureaucrats will follow them, not Obama.

IRS: Do It Right the First Time

Here's a nextgov article on an Obama proposal to move money into more after-the-fact tax auditing automation (the "Automated Under-Reporter System"). In other words, run more matches of 1040 data against other available databases. A trade group for government contractors criticizes the idea, saying IRS should focus on avoiding such things from happening.

In other words, suppose FSA issues a payment to a tax ID. It reports the payment to IRS. IRS expects the tax ID's 1040/tax return to reflect the FSA payment.

In my experience, asking IT people to do a batch match of two files was easy, and that seems to be what we're talking here. Yes, it'd be nice to avoid problems upfront, which is why FSA is supposed to be checking estate ID against death records and asking IRS to verify AGI is under the limits. But if the local landlord of an FSA/NRCS office forgets to report a rental payment, or the person who transcribes an appeal hearing forgets to report the services check, I've no problem with an after-the-fact check. People should pay their taxes, period, whether it's Wesley Snipes or Jane Doe.

Food Safety

NYTimes reports the food system seems to be more safe than it was 10 years ago. It's complicated because we're better at identifying problems than we were. "Industrial ag" can institute more controls, do more testing, police interfaces better, but a problem gets spread much wider. More organic and locavore agriculture depends less on technology and safeguards and more on the integrity and good practices of the farmer.

The Worst Question Today

Comes in the Washington Post from Howard Kurtz, writing on the fate of newspapers:

"Why did no establishment media company create a Craigslist, a Huffington Post, a Google News, a Twitter, or other sites that have altered the boundaries of news and information?"

The answer is twofold:

1. With the possible exception of Huffington Post, which I've never visited, the creators of the other sites were doing something different, but not trying to create "Craigslist", etc. Craigslist as it exists today is the result of a long evolution, it wasn't created in one go.
2. Established media companies, just as for any bureaucracy, spend their energies doing their established job. The publisher of the NYTimes doesn't come to work every day asking himself/herself: what are we going to do differently today? The workday is shaped by the expectations of his/her employees, advertisers, etc. The creator of Craigslist came to work everyday with no web of expectations--no one had ever seen a craigslist, so he was free to create it. (See the Christensen books for expansion of the point.)