This comment addresses Environmental Protection Agency’s request for advice in “developing an ‘analytic blueprint’ of materials on the technical merits and challenges of using economy-wide models to evaluate the social costs, benefits, and economic impacts associated with EPA’s air regulations.” The agency plans to present these materials to a new Science Advisory Board (SAB) panel with “expertise in economy-wide modeling.”…
Current television law makes programming agreements circuitous and distorts market forces. The Congressional Research Service says that “the negotiations between programmers and distributors, although private, are strongly affected by statutory and regulatory requirements and cannot be properly characterized as free-market.” Every television industry segment has received some regulatory favors though the decades. Most concerning is that there is “a thicket of communications law requirements aimed at protecting and supporting the broadcast industry,” as the Copyright Office has said.
That many nongovernmental stakeholder communities are electing to participate in Internet governance processes on their own account implies that governments lack the consent necessary to legitimately exercise a primary role.
It is not clear based on the FDA’s analysis whether its proposed rule is in the best interest of society. FDA makes no attempt to estimate the benefits of the regulation, and the analysis of the costs is very likely biased downward due to questionable assumptions and omissions. Further, changes of behavior are only selectively considered—discussing them when logically leading to benefits but dismissing the costs associated with those changes in behavior.
Supporters of the blackout rules—like some sports leagues and broadcasters—argue that forcing blackouts on cable and satellite providers helps maintain free over-the-air broadcasts. That specious argument should be disregarded. Unlike the 1970s, few Americans now rely solely on broadcast television for their entertainment, so the FCC’s ill-advised attempt to shape markets only inhibits free competition.
Architectural and Transportation Barriers Compliance Board
The regulatory process consists of many stages, but the essential first step is answering the question "what's the problem?" A thorough regulatory impact analysis should provide evidence that the regulation addresses a significant, systemic problem and trace that problem back to its root cause. A cursory or faulty analysis of the problem prevents regulators from devising an effective solution and considering realistic alternatives.