The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy

Dear Chairman King and Ranking Member Cohen:

My name is John D. Graham, Dean of the Indiana University School of Public and Environmental Affairs and former administrator of the Office of Information and Regulatory Affairs (OIRA) of the Office of Management and Budget (2001–2006). In my capacity as editor of an article series organized by the Mercatus Center at George Mason University and published in volume 37, issue 2 of the Harvard Journal of Law & Public Policy, I submit the attached articles as my written testimony for the Executive Overreach Task Force’s hearing on May 24, 2016, entitled “The Federal Government on Autopilot: Delegation of Regulatory Authority to an Unaccountable Bureaucracy.”

• John D. Graham and James W. Broughel, “Stealth Regulation: Addressing Agency Evasion of OIRA and the Administrative Procedure Act,” Harvard Journal of Law & Public Policy, Federalist Edition 1, no. 1 (2014).

• John D. Graham and Cory R. Liu, “Regulatory and Quasi-Regulatory Activity without OMB and Cost-Benefit Review,” Harvard Journal of Law & Public Policy 37, no. 2 (2014).

The viewpoints in my testimony do not necessarily reflect the viewpoints of the Mercatus Center at George Mason University or the School of Public and Environmental Affairs at Indiana University.

I also attach my “Truth in Testimony” disclosure form and a brief biography.

Sincerely,

John D. Graham, PhD
Dean, Indiana University School of Public and Environmental Affairs